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Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpretin g 



tFie~Secretarv of the Interior's 
Standards tor Rehabilitation 



■ % 



UNIVERSITY OF GEORGIA 

NOV 2 1985 

u lj,vrtiMto 

OEP0SIT0RY s 




Volume II 



Cover Illustration: The Times Building (also known as the Dome Building), Chattanooga, 
Tennessee. Rehabilitated under the historic preservation tax incentives program. 
Drawing by Judson Mclntire for the Historic American Buildings Survey. 1973. 



INTRODUCTION 



"Interpreting the Standards" bulletins were initiated in April 1980 by the 
Preservation Assistance Division (then Technical Preservation Services Division) to 
explain rehabilitation project decisions made by the National Park Service, U. S. 
Department of the Interior. Rather than describe every aspect of the overall 
rehabilitations in great detail, the bulletins focus on specific issues— alterations to 
storefronts, through-the-wall air conditioning, interior alterations—that posed 
problems in the review process. To this extent, then, the bulletins tend to emphasize 
limited aspects of a project and de-emphasize other aspects of the work that posed 
no special concerns or that were noteworthy or innovative. 

Issued at intervals to program administrators in National Park Service regional 
offices and State historic preservation offices, the first U3 "Interpreting the 
Standards" bulletins were collected in a single volume in 1982. Since then, 32 
additional bulletins have been issued. The present compilation includes these 
bulletins, bringing the total to 75. 

"Interpreting the Standards" bulletins are designed for use primarily by program 
administrators at the State and Federal level who make recommendations and 
decisions on rehabilitation projects. The bulletins are case-specific and are not 
necessarily applicable beyond the unique facts and circumstances of each case. 
Many of the bulletins present projects denied certification by National Park Service 
regional offices that were later appealed to the Chief Appeals Officer. While the 
final decisions in these cases have been incorporated into the discussions of such 
projects, appeal decisions are individual and are made on the facts and circumstances 
specific to the project, including information on aspects of a project that are not 
treated in the bulletin itself. Consequently, care should be taken not to consider 
portions of appeal decisions quoted as directly applicable to other projects of a 
generally similar nature. Appeal decisions do not accumulate as precedent in the 
legal sense. The procedures for obtaining certifications of rehabilitation are 
explained in Title 36 of the Code of Federal Regulations, Part 67. These regulations 
control in the event of any inconsistency with these bulletins. 

The following ten Standards for Rehabilitation are used by the Secretary of the 
Interior to determine if a rehabilitation project qualifies as "certified rehabilitation" 
pursuant to sections 48(g), 167(o), and 191 of the Internal Revenue Code. The 
Standards comprise the sole regulatory basis for determining whether or not a 
rehabilitation is consistent with the historic character of the structure or the district 
in which it is located. The applicable Standards as well as project conformance or 
nonconformance to those Standards are referenced at the top of each bulletin in 
italics. 

1. Every reasonable effort shall be made to provide a compatible use 
for a property which requires minimal alteration of the building, 
structure, or site and its environment, or to use a property for its 
originally intended purpose. 

2. The distinguishing original qualities or character of a building, 
structure, or site and its environment shall not be destroyed. The 
removal or alteration of any historic material or distinctive 
architectural features should be avoided when possible. 



3. All buildings, structures, and sites shall be recognized as products of 
their own time. Alterations that have no historical basis and which seek 
to create an earlier appearance shall be discouraged. 

k. Changes which may have taken place in the course of time are 
evidence of the history and development of a building, structure, or site 
and its environment. These changes may have acquired significance in 
their own right, and this significance shall be recognized and respected. 

5. Distinctive stylistic features or examples of skilled craftsmanship 
which characterize a building, struture, or site shall be treated with 
sensitivity. 

6. Deteriorated architectural features shall be repaired rather than 
replaced, wherever possible. In the event replacement is necessary, the 
new material should match the material being replaced in composition, 
design, color, texture, and other visual qualities. Repair or replacement 
of missing architectural features should be based on accurate 
duplications of features, substantiated by historic, physical, or pictorial 
evidence rather than on conjectural designs or the availability of 
different architectural elements from other buildings or structures. 

7. The surface cleaning of structures shall be undertaken with the 
gentlest means possible. Sandblasting and other cleaning methods that 
will damage the historic building materials shall not be undertaken. 

8. Every reasonable effort shall be made to protect and preserve 
archeological resources affected by, or adjacent to any project. 

9. Contemporary design for alterations and additions to existing 
properties shall not be discouraged when such alterations and additions 
do not destroy significant historical, architectural or cultural material, 
and such design is compatible with the size, scale, color, material, and 
character of the property, neighborhood or environment. 

10. Wherever possible, new additions or alterations to structures shall be 
done in such a manner that if such additions or alterations were to be 
removed in the future, the essential form and integrity of the structure 
would be unimpaired. 

Bulletins are arranged in order of issuance. The number assigned to each is 
composed of the fiscal year in which the bulletin appeared and an overall cumulative 
number (e.g., 83-046, 85-072). Each bulletin bears the name of the author. The 
index provided at the end of this volume references all bulletins in the series. It keys 
the bulletins to particular Standards and to such topics as Abrasive Cleaning, Roof 
Alterations, and Windows. A looseleaf format has been followed in order to allow for 
easy removal for xeroxing as well as for easy insertion of future supplements. 



This material is not copyrighted and can be reproduced without penalty. However, 
normal procedures for credit to the authors and the National Park Service are 
appreciated. "Interpreting the Secretary of the Interior's Standards for 
Rehabilitation," has been developed under the technical editorship of Lee H. Nelson, 
FAIA, Chief, Preservation Assistance Division, National Park Service, U. S. 
Department of the Interior, P. O. Box 37127, Washington, D.C. 20013-7127. 
Comments on the usefulness of this information are welcomed. 

Additional information and guidance on technical preservation and rehabilitation 
techniques for historic buildings may be found in the Preservation Briefs, Technical 
Reports, and Preservation Case Studies developed by the Preservation Assistance 
Division. For a complete list of publications including price and GPO stock number 
information, write to: The Preservation Assistance Division at the above address. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



the~Secretary of the Interior's 



"Standards tor Rehabilitation 



Number: 83-044 

Applicable Standard: 2. Preserving the Distinguishing Character of a 

Building (nonconformance) 

Subject: PORCH ALTERATIONS 

Issue: Porches are a very common and often dominant feature on the primary facades 
of many residential buildings and yet represent that portion of a building which is 
often subjected to insensitive changes. The size of the porch, its architectural style, 
the ornateness or simplicity of detailing, the sense of openness, and delineating 
features such as columns and balustrades, are all important attributes. "Interpreting 
the Standards" No. 82-033 discusses problems and concerns with enclosing historic 
porches, a change which is often sought by owners undertaking rehabilitation in order 
to gain additional year-round living space. Porches may also suffer from owners' 
attempts to deal with inherent maintenance problems that often stem from the nature 
of their construction and exposure to the effects of weathering and decay. Encasing a 
decorative but deteriorated balustrade, removing or simplifying brackets and 
fretwork, or boxing-in open eaves are all usually inappropriate alterations to an 
architecturally significant porch. Work that at first glance may be considered only a 
small physical change to a porch can often have a major impact on the historic or 
architectural character of the building and be clearly in violation of the Standards as 
in the case described below. 

Application: An early twentieth-century frame house was one of many buildings in a 
historic district undergoing extensive renovation work by a single developer. The 
house is somewhat unusual in that it was apparently built as a duplex in an area of 
mostly single family houses. The twin porch design is thus both historically and 
architecturally significant in its contribution to the character of the building (see 
illus. 1). In the course of the rehabilitation, the developer connected the two porches 
with a new eight-foot section, purportedly to shelter the steps from the rain (see illus. 
2). Both the State Historic Preservation Officer and the National Park Service 
considered this treatment as a violation of Standard 2, thus precluding certification of 
rehabilitation despite the rest of the work being handled in a sensitive manner. In 
rebuilding the porch to extend across the entire front, the following changes had 
occurred: 

1. The historic twin porch design was lost; 

2. A strong horizontal element created by the large continuous porch 
was created for the first time; 

3. The projecting center portion of the duplex was interrupted by the 
porch, obscuring this original strong architectural feature; and, 

4. The historical and architectural character of the building as a duplex 
was substantially diminished. 



8 3- cm 

The sole justification for the porch alteration was the need to alleviate water 
accumulation at the steps. Traditionally, such porch roofs were pitched away 
from the steps and the building in order to properly shed water; the owner should 
have thus repaired the porch and added gutters and downspouts, as necessary, to 
correct the water problem. 

After considering the tax implications of denial of certification and the cost of 
undertaking corrective measures, the owner offered to remove the porch linkage 
and was subsequently advised by the appeal hearing officer that such a measure 
would bring the project into conformance with the Standards and would lead to 
certification of rehabilitation. 

Prepared By; Charles Fisher, TPS 



These bulletins are issued to explain preservation project decisions made by the 
U.S. Department of the Interior. The resulting determinations, based on the 
Secretary of the Interior's Standards for Rehabilitation, are not necessarily 
applicable beyond the unique facts and circumstances of each particular case. 



83-(m 




1. Prior to rehabilitation, the historic 
twin porch design and center projecting 
bay were strong architectural features. 




2. In connecting the two historic porches, 
the twin porch design was lost; a strong 
horizontal element was created by the 
large continuous porch; and the sense 
of a duplex building was diminished. 
To obtain certification, the owner 
agreed to restore the porch. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



the~Secretary of the Interior's 



Standards tor Rehabilitation 



Number: 83-045 

Applicable Standards: 2. Retention of Distinguishing Architectural 

Character (nonconformance) 
9. Compatible Contemporary Design for New 
Alterations/ Additions (nonconformance) 

Subject: REPLACING NONSIGNIFICANT LATER ADDITIONS 

Issue: One aspect of overall rehabilitation work may involve replacement of a 
deteriorated nonsignificant later addition with a new addition in order to meet certain 
functional needs. An example of such work is the replacement of previously existing 
enclosed vestibules both for convenience to patrons and to highlight business 
entrances. Whatever the reason for a new addition, all contemporary design must 
conform to Standards 2 and 9; that is, it must be neither visually intrusive nor 
physically damaging to historic building material. 

Application: A nine-story, late Victorian brick and brownstone commercial building 
located in a historic district within a large northeastern city was being rehabilitated 
for use as a multi-purpose business and shopping complex (see illus. 1). When the 
proposal for extensive interior and exterior work was forwarded by the State Historic 
Preservation Officer to NPS for review, NPS concurred with the State's general 
assessment of nonconformance with the Secretary's Standards and denied 
certification, listing violations of Standards 2, 5, 6, and 9. Exterior work cited for 
nonconformance included window alterations and the design for new glass canopies to 
cover areaways flanking a main entrance. Nonconforming interior work included 
demolition of an existing skylight; large cuts in the main floor; introduction of a 
mezzanine; and construction of two curved staircases linking the interior levels. 

Rather than appeal the denial, the owner chose to revise the project plans and over a 
ten-month period worked with NPS staff so that the entire project might be 
reconsidered. After all major components of the proposed interior work had been 
satisfactorily resolved, the one exterior item still being negotiated was the design of 
the two new glass and metal canopies to replace the two deteriorated wooden 
vestibules (see illus. 2). (The need per se for canopies to replace existing non- 
significant coverings had never been disputed from either the standpoint of patron 
convenience or commercial viability.) 

The architect's initial design for the glass and dark colored anodized aluminum 
canopies incorporated a standard vault with a flat roof section which NPS felt was a 
visual intrusion upon the substantially unaltered facade. Although there would be no 
destruction of historic material, the curved roof line of the proposed canopy extended 
well above the level of the earlier vestibule and obscured the lower portion of the first 
floor windows, a distinguishing feature of the building (see illus. 3). For the overall 
project to meet the Standards, NPS informed the owner that any new canopy would 
have to be located below the sill of the first floor windows. In response, the architect 
prepared one alternative design for the canopies which met the height condition, but 
which— both NPS and the owner agreed— introduced several other design problems (see 
illus. k) which might affect pedestrian safety. 



83-045 

At a later date, citing these problems and increased construction costs, the owner 
again sought approval of the initial design. NPS continued to maintain its earlier 
position that the initial design did not meet the Standards but felt that alternative 
canopy design options still existed that would meet the Standards yet at the same time 
be practical and esthetically pleasing. At this point, the owner elected to appeal 
the denial, seeking approval of the overall project including the initial canopy design. 
Prior to the hearing, however, the architect submitted two new scaled-down 
alternatives for the glass canopies, both of which were approved by NPS (see illus. 5), 
thus enabling the entire project to be certified. Following project approval, the 
Option "A" canopy was actually constructed (see illus. 6). 

Prepared By: Kay D. Weeks, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



83-045 





^1. East elevation showing wooden 
vestibules flanking main entrance, 
added c. 1920. 



il. Deteriorated condition of vestibule. 



83-045 





3. Initial canopy design was not approved 
by NPS because its height obscured the first 
floor windows. 



4. Revised canopy design met the NPS he 
condition but introduced potential pedestr 
safety problems. 




Option A 




5. Final canopy designs (Option A and B), both of which NPS approved. The Option A 
design was ultimately constructed. 



*OT 



83-045 
f 




6. The Option A entrance canopy in place. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



ffie~Secretarv of the Interior's 



Standards tor Rehabilitation 



Number: 83-046 



Applicable Standards: 



3. 
6. 



9. 



Recognition of Historic Period (nonconformance) 
Repair/Replacement of Deteriorated or Missing 
Architectural Features Based on Historical 
Evidence (nonconformance) 
Compatible Contemporary Design for New 
Alterations/ Additions (nonconformance) 



Subject: WINDOW ALTERATIONS: 



Inappropriate Contemporary Design 
Inappropriate Historic Appearance 



Issue: In rehabilitating historic buildings, property owners may sometimes consider 
replacing original windows with those of a different design, not only to reduce 
maintenance and energy costs but to try to "improve" or "enhance" the appearance of 
the building. For example, some owners believe that next to cleaning or repainting, 
the easiest way to give an office building a new look is to install a contemporary 
window and use tinted glass to serve as a sharp contrast between the old and the 
new. Another unfortunate approach is to remove the original windows and install a 
window design from a different historic period in an effort to make the building look 
either older or grander than it actually is. On the other hand, the recommended 
approach— according to the Standards—is to preserve historic features such as 
windows, whenever possible. If energy conservation is an integral part of the planning 
objective in order to make a project economically viable or to meet regulatory 
requirements, ways of improving the performance of the existing windows should 
always be explored first. Then, if windows cannot be easily repaired, an evaluation 
should be made to determine their contribution to the overall architectural character 
of the building before any replacement proposal is considered. 

Throughout the planning process, however, changing the historic window design to 
"improve" or "enhance" the appearance of the building should not be considered. If the 
windows are a distinguishing feature of the historic building and must be replaced 
because of their physical condition, they should be duplicated as closely as possible in 
accordance with Standard 6. Where the windows are not significant in their own right 
but are located on significant facades, there is more flexibility in the type of 
replacement windows that can be installed. However, even within this more flexible 
context, the replacement window units should never give the building a "historic" 
appearance it never had (Standard 3), nor should a design be selected that is 
incompatible with the historic character of the building (Standard 9). 

Application: Inappropriate Contemporary Design 

Constructed in 1911 with a white glazed brick covering the upper floors, this 
individually listed National Register property is a visually prominent and 
architecturally significant building, located in a small southern town (see illus. 1). As 
the National Register nomination indicated, "at the ends of the building each of the 
upper floors had three double-hung windows. On the south side each floor had seven 
pairs of double-hung windows. The windows collectively provided very bright and 
agreeable work space inside the building." The building has a relatively austere facade 



83-046 

reflecting its commercial character and results in the simple double-hung windows 
becoming a significant design feature. 

In the course of rehabilitating the building for mixed commercial and residential use, 
the double-hung clear-glazed wooden windows were removed (and stored) and replaced 
with metal windows with a single vertical division created by a meeting rail. In 
addition, a dark tinted glass was used in place of the original clear glazing (see illus. 2 
and 3). The change in the design and the use of dark tinted glass gave the new 
windows a strong contemporary look not in keeping with the historic character of the 
building. Upon submitting a certification application, the owner was advised that the 
window alterations did not meet numbers 2, 5, 6 and 9 of the Secretary's Standards. 

The owner was further advised by NPS that the original double-hung wooden windows 
were typical of the time in terms of technology and design consideration and for the 
building were a significant feature. As such, the windows should have been repaired 
and if that was not practical, the replacement units should have matched the 
configuration of the original double hung sash and the reflective qualities of the 
glass. Representatives from both the state historic preservation office and the NPS 
regional office inspected the completed project and observed major changes in the 
design and the reflective qualities of the windows. With the new dark tinted glass and 
dark trim finish, the windows now appear as dark voids, contrasting with the white 
glazed brickwork. The denial of certification by the regional office was sustained on 
appeal by the owner. 

Application; Inappropriate Historic Appearance 

Plans for the rehabilitation of a small late nineteenth century cottage, located in a 
historic district in the South, were submitted prior to undertaking the work. After the 
determination was made by NPS that the proposed work met the Standards, the owner 
elected to revise the plans to include the removal of the two original first floor 
windows and subsequent replacement with floor-to-ceiling windows (see illus. 4 and 
5). Upon completing the work and requesting final certification the owner was advised 
by NPS that the introduction of the new sash and exterior shutters which extend to the 
porch floor created a design feature that never existed in this particular structure and 
gave the building an inappropriate historic appearance. Moreover, NPS indicated to 
the owner that this particular type of window generally was found in buildings of an 
earlier period in that area. 

On appeal the owner provided sufficient evidence to show that such large windows 
were common in the local historic district but acknowledged that he had removed the 
original windows in rehabilitating his building. When the appeal hearing officer 
sustained the decision that the project did not meet Standard 3, the owner offered to 
reinstall the original sash, which had been restored for use in another building. The 
corrective work has since been undertaken and the project certified (see illus. 6). 

Prepared by; Charles E. Fisher, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



83-046 





*4 ll kS ' ~ 

III ■■ ll n,. 





■■^^■^M*" 



I The original windows were of clear 
lazing and were of a one over one pane 
:onfiguration. 



2. New windows with dark tinted glass 
and a vertical division on the upper floors 
were not in keeping with the character of the 
building. 




> 



3. Close-up view shows the vertical 
division used in the new windows. 



83-046 





k. The 1880s cottage was in deteriorated 
condition prior to rehabilitation. Ghost 
marks of missing porch are evident. The 
original 2 over 2 windows had survived on 
the front and were to be repaired according 
to the plans submitted to NPS for prior review. 



5. In the course of rehabilitation 
the owner elected to remove the original 
windows and install new ones in a historic 
design which extended to the first floor. 
Full-length blinds were also added. 




6. After the work was determined not to meet the 
Standards because of the window alterations, the 
owner proceeded to reinstall the original ones and 
thus obtained certification. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



the Secretary of the Interior's 



Standards tor Rehabilitation 



Number: 83-047 



Applicable Standards: 1. Compatible New Use (nonconformance) 

2. Retention of Distinguishing Architectural 

Character (nonconformance) 
5. Sensitive Treatment of Distinctive Features 

and Craftsmanship (nonconformance) 
10. Reversibility of New Alterations/Additions 

(nonconformance) 



Subject: INTRODUCING NEW OPENINGS INTO MAJOR ELEVATIONS 

Issue: The introduction of new window or door openings to accommodate new 
functions is a common component of projects submitted for rehabilitation 
certification. In most cases, a limited number of new openings cut in party walls 
or other non-significant elevations will not alter the historic character of a 
building. On the other hand, where such openings are introduced on a principal 
facade, the loss of significant historic building material, change in rhythm of the 
bays, or other nonconforming treatments that, together, destroy the historic 
building's essential form and integrity, will generally result in denial of 
certification. 

Application: An abandoned Elks lodge located in a historic district was proposed 
for reuse as the home office of a life insurance company. Located on a site that 
slopes steeply down from front to back, the building has two stories on the front 
facade and three on the rear elevation (see illus. 1 and 2). Since the building 
occupies the full width of a city block, both the facade and rear elevations front 
directly on streets. The facade is highly ornamented in the Second Renaissance 
Revival style, while the rear elevation is less ornately decorated. 

Because office use would require more parking than was available on the street or 
in adjacent lots, the developers proposed incorporating a parking facility at the 
basement level in the rear of the building. The SHPO and the NPS regional office 
approved the concept of parking in this portion of the basement, a space which 
had been used as a gym. 

The location of the driveway entrance to the parking area posed a problem, and 
became the issue over which the project ultimately was denied certification. The 
best location would have been on the less ornately decorated rear elevation. The 
plan originally considered by the developers to locate the entrance at the rear, 
however, contained a ramp that the city traffic engineer would not approve. As a 
result, the entrance was proposed for the main elevation (see illus. 3). The 
regional office felt this design adversely affected not only the facade's character 
and historic fabric, but also would destroy significant fabric located inside the 
building in a library (see illus. 4). 



83-047 



In its letter of denial to the developers, the regional office wrote: 

The introduction of the garage entrance on the principal facade 
alters the character of that well-detailed, Second Renaissance 
Revival-style facade. Not only does it result in the demolition and 
removal of historic material of significance, but it would would also 
interrupt the rhythm and balance that is characteristic of this 
symmetrical facade (Standard 2). In addition, significant 
architectural features of the library—the bookcases, fireplace 
mantel, and decorative frieze—would be lost if the garage entrance 
is constructed as proposed (Standard 5). The Standards recommend a 
compatible use for a building that requires minimal alteration 
(Standard 1). Parking which requires a major opening on a principal 
facade cannot be considered a compatible use requiring minimal 
alterations. It is irreversible and destroys the form and integrity of 
that facade. The essential form and integrity of the structure 
should be unimpaired should alterations be removed in the future 
(Standard 10). While this office recognizes the arguments presented 
on the parking issue, the rehabilitation still must be consistent with 
the historic character of the structure and the Standards. 

Rather than appeal the regional office's decision, the architect for the developers 
redesigned the parking space, placing the entrance at the rear of the building. The 
new design was acceptable to the city traffic engineer. 

The resubmitted design was approved by the regional office, and construction on 
the project is going forward. 



Prepared by; William G. MacRostie, TPS 



These bulletins are issued to explain preservation project decisions made by the 
U.S. Department of the Interior. The resulting determinations, based on the 
Secretary of the Interior's Standards for Rehabilitation, are not necessarily 
applicable beyond the unique facts and circumstances of each particular case. 



83-047 




1. Front Facade 




2. Rear Elevation 



83-047 




^&M^mmm$&SiM 



3. The original parking entrance proposed for the 
facade. The balustrade over the entrance was 
intended to serve as a visual "connector" to similar 
original features on the facade. The library slated 
for partial demolition is located behind the 
proposed entrance. 




4. The parking entrance through the library would 
have necessitated removal of the fireplace and 
bookshelves. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



tFieSecretarv ot the Interior's 



Standards tor Rehabilitation 



Number: 83-048 

Applicable Standard: 2. Retention of Distinguishing Architectural 

Character (nonconformance) 
5. Sensitive Treatment of Distinctive Features 
and Craftsmanship (nonconformance) 

9. Compatible Contemporary Design for New 
Alterations/ Additions (nonconformance) 

10. Reversibility of New Alterations/ Additions 
(nonconformance) 

Subject: INAPPROPRIATE EXTERIOR ALTERATIONS: WAREHOUSE TO 
APARTMENTS 

Issue: In order to market abandoned and functionally obsolete historic buildings, 
owners are often tempted to make major alterations as a statement of the new 
life and vitality of the area and in order to accommodate the new use of the 
building. This is particularly true when warehouse buildings are converted to 
apartments. Not only must these large buildings be modified to meet light and 
ventilation code requirements for residences, but they must often compete with 
modern new construction nearby that has highly marketable amenities. 

Some types of buildings can more easily accommodate new uses and alterations 
than others. Nineteenth-century warehouses, with thick masonry walls and small 
window openings, present a particular challenge to owners; depending on the 
design of the particular warehouse, the alterations that can be made to the 
building without destroying its historic warehouse character may be limited. The 
key is identifying the distinguishing architectural features of the building and then 
planning a rehabilitation that allows for the retention of these features. 

If the proposed alterations do not conform to the Secretary of the Interior's 
Standards for Rehabilitation and as a result, the historic character of the building 
is destroyed, the project cannot be certified for tax benefits. 

Application: A circa 1890s six-story brick tobacco warehouse located in a historic 
waterfront district was purchased for conversion to 204 apartments and first floor 
commercial space. The building was in good condition, although it had been 
vacant for many years. The city hoped that the conversion of this warehouse to 
apartments would be the first step in revitalizing this portion of the waterfront 
area, particularly since the building was the largest in the primarily residential 
district and formed the corner of the historic district boundary. A market study 
was commissioned by the owners to determine what changes would be necessary to 
make the building marketable. The study recommended that at least 85% of the 
residential units have a waterfront view, that a portion of the interior of the 
building be removed to provide necessary light and ventilation to meet code 
requirements, that some of the windows be widened as well to meet code 
requirements for light and ventilation, that all units have an exterior balcony and 
that a seventh floor be added to the structure to increase the number of rentable 



83-048 

units. This information was then used by the architect to develop the 
rehabilitation plan. 

The state historic preservation office had worked closely with the owners in the 
evolution of the design and strongly recommended certification of the project. 
The regional office, however, reviewed the project and expressed concern over a 
number of the proposed changes. The most drastic alteration to the building was 
the proposal to create an interior court with a waterfront orientation by removing 
7 of the 17 bays of one facade. Two other controversial changes proposed were to 
widen the windows in select vertical bands, and to attach lightweight metal 
balconies to the exterior. While there was also concern for the cumulative effect 
of the other proposed changes, these three issues resulted in regional denial of 
certification for the project based on Standards 2, 5, 9, and 10. These changes 
would have altered the historic character of the warehouse building by removing 
historic material, by failing to respect the skilled craftsmanship of the building, 
and finally, by incorporating incompatible and non-reversible elements of new 
work. The owner, with the support of the State, appealed the decision of the 
regional office. 

In reviewing the proposed changes, the appeals hearing officer determined that 
the architectural elements that contributed to the historic character of the 
building should be clearly outlined: e.g. the massiveness of the 200' x 400' 
structure; the highly articulated facades composed of alternating bands of 
windows openings and pilasters; and the vertical effect of these bands with a 
hierarchy of openings from the ground floor to the top floor complemented by the 
horizontal beltcourses, top floor frieze and corbelled cornice. The brickwork was 
well executed and even with the substantial detail on the surface of the building, 
the facade retained a strong sense of flatness as there were no deep surface 
penetrations (see illus. 1). In summary, the architecture of the warehouse was 
very sophisticated for this type of construction and was significant both to the 
building and to the 19th-century district in which it was located. 

Following an onsite inspection of the warehouse and the district, the hearing 
officer sustained the denial of the regional office for a number of reasons. He 
felt that the planar quality of the exterior walls would be drastically altered by 
the addition of projecting balconies with their inherent shadow lines (see illus. 2). 
He felt that widening selected bands of windows would interrupt the regular 
rhythm of the window bays. Widening the upper floor windows would also alter 
the hierarchy of window openings from large openings on the first floor to the 
small openings on the top floor. His last major concern was the proposed cut in 
the building, which not only removed the significant original materials of the 
facade, but altered the massive quality of the warehouse structure (see illus. 3). 

While sustaining the decision of the regional office, the hearing officer 
encouraged the owner to reconsider the proposed changes to the building and 
resubmit his application with a proposal that would meet the Standards. While the 
hearing officer felt that the building could not accommodate any external 
projecting balconies, he felt that an atrium court that did not remove any of the 



83-0^8 



facade and a modified scheme for widening the windows that reflected the 
hierarchy of existing openings could be considered. 



Prepared by: Sharon C. Park, AIA, TPS 



These bulletins are issued to explain preservation project decisions made by the 
U.S. Department of the Interior. The resulting determinations, based on the 
Secretary of the Interior's Standards for Rehabilitation, are not necessarily 
applicable beyond the unique facts and circumstances of each particular case. 











1. The existing south elevation of the 1890s warehouse building with its 
alternating bands of pilasters and window openings. The size of the 
openings decreases as the building progresses from the base to the top 
floor. The brickwork was quite sophisticated for a warehouse structure. 



83-048 



■ 




2. The proposed south elevation with bands of projecting balconies. The 
window openings would be widened or lengthened in order for each of the 
204 apartment units to have one balcony. Not only would the windows be 
altered in selective bands, but the proposed balconies would create deep 
shadow lines on the facade. While the owner felt that the balconies were 
a reversible feature that could be removed in the future, the hearing 
officer determined that both the visual clutter of the balconies and the 
change in the hierarchy of the window openings did not meet the 
Standards. 




3. Perspective view of the proposed changes snows the large courtyard 
and the removal of seven bays of the waterfront facade in order to 
provide a water view for 85% of the apartment units. The hearing officer 
determined that the loss of significant original historic material and the 
drastic change in character created with the new "U" shaped plan did not 
meet the Standards. The projecting balconies and widened windows were 
also cited as not meeting the Standards. The setback rooftop addition, 
however, was not a concern as it would not have been visible from the 
street level of the historic district. 



jchnical Preservation Services 
■eservation Assistance Division 
ational Park Service 
S. Department of the Interior 
'ashmgton, D.C. 



Interpreting 



thlTSecretarv of the Interior's 



"Standards tor Rehabilitation 



Number: 83-049 



Applicable Standards: 2. Retention of Distinguishing Architectural 

Character (nonconformance) 
6. Repair/Replacement of Deteriorated or Missing 
Architectural Features Based on Historical 
Evidence (nonconformance) 
9. Compatible Design for New Alterations/ Additions 
(nonconformance) 

Subject: INAPPROPRIATE STOREFRONT ALTERATIONS 

Issue: Storefronts frequently define the historic character of commercial buildings. 
Entrances and display windows are particularly important features of storefronts; the 
number of entrances and their placement in relation to windows can create a distinct 
rhythm on the primary facade that should be retained in the course of a rehabilitation. If 
new entrances are required because of code requirements or new interior use, their 
design and placement should not detract from the importance of the storefront to the 
building. 

Application: A commercial building, located in a historic district and constructed circa 
1880-90, was enlarged from three bays to seven bays sometime around 1900 (see illus. 1 
and 2). The added storefront, consisting of double doors flanked by window bays, 
duplicated the original storefront. The two fronts were separated by a narrower bay 
containing a single door. 

In the most recent rehabilitation, which converted the building to office space, the 
owners replaced the two sets of double doors with windows copied from those existing in 
other bays of the storefronts. To accommodate ground floor offices, an arched entrance 
was added to the side elevation (see illus. 3). The design for this doorway echoed an 
interior doorway and an arched entrance on a neighboring building. The original side 
entrance was replaced with a window. 

The regional office denied certification to this project, citing Standards 2, 6, and 9. The 
State Historic Preservation Office supported this decision. In its evaluation, the region 
noted that "the new arched entrance is not compatible in character with the exterior of 
the building as a whole, as the design of the new entrance bears no similarity to the 
building's other window and door openings." Equally important in the denial were the 
changes to the storefronts, which were "significantly altered by conversion of two, 
original entrances to windows and by the consequent removal of the original 
transoms. Although the removed doors themselves may not have been original, the 
placement of entrances as they were, with double doors and a transom between the 
windows, constituted a distinct rhythm to the storefront." 

The owners appealed, stating that the doors they replaced with windows were not 
original, and were badly deteriorated. The new windows, on the other hand, matched 



83-049 

the existing windows, thus "creating an elegant front with distinct 'rhythm.'" They 
also contended that the arched side entrance was consistent with the character of the 
structure since it was patterned on an existing interior arch and reflected entrances 
on neighboring buildings. 

Upon appeal, the decision of the regional office was sustained. The chief appeals 
officer noted that the "two entrances were an important part of the commercial 
character and architectural detailing of the storefront facade." Furthermore, the 
"functional relationship of the storefront facade to the partially blank wall on the 
ground floor of the /side/ facade also reflected the commercial use within this portion 
of the building." The new entrance on this facade introduced a major new design 
element into the "strong rectilinear character of the building." This change further 
diminished the importance of the storefront to the structure. 

Prepared by ; Michael Auer, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



83-049 




la. 



la. and lb. Historic photograph (la) showing original three-bay storefront 
building (ca. 1880- 1890). With minor alterations, this storefront survived 
until most recent rehabilitation. Side door led to second floor 
apartments. Drawing (lb) shows the building's main features clearly. 




lb. 



83-0^9 




2a. 



2b. 



2a. and 2b. Building as it looked after ca. 1900 enlargement. Two 
identical storefronts (double doors flanked by window bays) were 
separated by a bay containing a single door. 




3a. 



3d. 



3a. and 3b. After rehabilitation. Double doors on the front have 
been replaced with windows, an arched side entrance has been cut, 
and the former side entrance has been replaced with a window. 



chnical Preservation Services 
?servation Assistance Division 
tional Park Service 
3. Department of the Interior 
ishmgton, D.C. 



Interpreting" 



the Secretary of the Interior's 



Standards tor Rehabilitation 



Number: 83-050 



Applicable Standards; 2. Retention of Distinguishing Architectural 

Character (Conformance) 
9. Compatible Contemporary Design for New 
Alterations /Additions (Conformance) 

Subject; NEW OPENINGS IN BLANK EXTERIOR WALLS 

Issue: A change of use of a historic structure may necessitate cutting new openings for 
windows or doors in blank exterior walls. Usually, such blank walls are secondary 
elevations, i.e., those exterior walls without special architectural treatment or emphasis 
such as common or party walls, or the side or rear walls that are not readily visible from 
the main thoroughfare. However, for some building types, such as ice houses, grain silos, 
creameries, etc., blank walls are highly significant to a building's character. New 
openings that would alter this character would not be approved. Therefore, owners 
contemplating new openings should be careful not to consider a blank wall a "throwaway" 
feature but should design the new openings to conform with Standards 2 and 9 and to be 
subsidiary elements in the overall building. If the design for new openings makes such a 
strong architectural statement as to change the appearance of the building radically or 
overwhelm the historic facades, certification of the rehabilitation will be denied. 

Application; An 1880's Romanesque Revival warehouse in a midwestern city was 
converted into luxury office space. The 5-story brick warehouse was actually two long, 
narrow buildings divided by a central load-bearing masonry wall. The north (street) wall 
was the principal facade and contained virtually all of the architectural and stylistic 
details (ornamental brickwork, windows, storefronts). The west wall was a blank brick 
wall covered with a sprayed-on stucco-like coating for weather protection and may have 
been a party wall originally although it has been exposed for some time. The first floor 
1960's aluminum and glass storefronts were without intrinsic significance (see ilius. 1). 
The building was individually listed in the National Register as one of the few remaining 
nineteenth century warehouses in an area that is now almost exclusively new high-rise 
hotels, offices, a convention center, and vacant lots. 

In planning for the rehabilitation of this warehouse, the owner determined that the only 
economically viable use was as luxury office space and that increasing the attractiveness 
of the space would require introducing windows into the blank west wall. Although the 
east wall did have some existing windows, the central load-bearing wall precluded 
"borrowing" natural light from the east across the width of the building. Additionally, 
the owner discovered that severe water damage had left the northwest corner of the 
warehouse structurally unsound and that part of the west wall would have to be rebuilt 
from the ground up. 

The rehabilitation, developed in close cooperation with the State, incorporates the new 
window openings into the rebuilt section of the west wall. The new windows are similar 
in size, shape, and rhythm to the windows on the primary north wall but the brickwork, 
sash, and glazing are clearly contemporary. The new brickwork is a slightly different 
color from the original and flush around the new windows rather than projecting; the sash 
is aluminum and a different color from the original, and the glazing is single-light. In 
rehabilitating the north facade, the owner carefully repaired the existing 2-over-2 
wooden double-hung sash (see illus. 2). 



83-050 

The non-significant 1960's storefronts were removed and replacement storefronts were 
constructed, although the new use of the building might not include retail on the first 
floor. The replacement storefronts incorporate new matching brick and stone piers and 
new wooden windows and multi-light transoms. The newly constructed west wall also 
incorporates two "storefront bays" but uses a less decorative brick pier and plain 
transoms in order to continue the differentiation between the historic north facade and 
the contemporary section of the west wall. The entrance was moved from its 1960's 
location in the center of the north facade to the northwest corner of the building. 
Access is through open storefront bays from both the north and west which create a 
recessed entrance at the corner of the building (see illus. 2). 

In denying certification of the rehabilitation, the regional office stated that: 

This new facade competes with the original front facade for perception as the 
dominant design element of the building. There would be acceptable ways of 
adding windows to a blank and insignificant wall, if the alteration retained 
the simple and secondary character of the facade. The new wall and windows 
already installed in this building attract much attention, make a strong 
architectural statement, and are located on the side of the building most 
visible from the nearest major intersection. The new design violates 
Standards 2 and 9. 

The other reasons for denial of certification related to the recessed entrance, which was 
determined to be uncharacteristic of the original storefront in violation of Standards 5, 
6, and 9. The owner, with the strong support of the State, appealed this decision. 

During the appeal the owner provided photographs that had been unavailable to the 
regional office at the time of the initial review. These photographs clearly show the 
juxtaposition of the new west wall, which reads as a compatible, contemporary design, 
and the original north facade (see illus. 2). They also demonstrate that from one major 
intersection, the original north facade is the most visible and that from the other major 
intersection, the west wall will be almost completely obscured upon completion of a new 
hotel to be constructed on the adjacent lot. 

The Chief Appeals Officer overturned the regional office denial and determined that the 
project met the Standards, providing that a wooden column was installed at the center of 
the north entrance bay to maintain the rhythm of the storefronts. In certifying the 
project, the Chief Appeals Officer said of the new openings in the western wall: 

The resulting new construction, successfully repeating window sizes and 
shapes from the original facade, reads as a clearly recent and subsidiary 
statement. This is due to the use of frankly contemporary details: flush 
brickwork of a slightly different color from the old construction; aluminium 
windows, again of a different color from the old; and single-light sash. 

The owner installed the required column and the project was certified. 

Prepared by: Sara K. Blumenthal, PAD 



These bulletins are issued to explain preservation project decisions made by the U. S. 
Department of the Interior. The resulting determinations, based on the Secretary of the 
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique 
facts and circumstances of each particular case. 



83-050 




1. North and west facades of warehouse. 

The 1960's storefronts are non-significant. 



2. New windows and 
entrance on west 
facade. Certification 
was conditional upon 
owner adding a wooden 
column in center of 
westernmost storefront, 




schnicai Preservation Services 
■eservation Assistance Division 
ational Park Service 
.S. Department of the Interior 
Washington, D.C. 



Interpreting^ 



the Secretary of the Interior's 



"Standards tor Rehabilitation 



Number: 83-051 



Applicable Standards: 2. Retention of Distinguishing Architectural 

Character (conformance) 

9. Compatible Design for New Alterations/Additions 
(conformance) 

10. Reversibility of New Alterations/Additions 
(conformance) 



Subject : CONTEMPORARY ADDITIONS 

Issue : The economic viability of some rehabilitations is dependent on the construction of 
new space for additional rental income or for the housing of new services which cannot 
be accommodated in the historic structure. In order to meet the requirements of the 
Secretary of the Interior's "Standards for Rehabilitation," particularly numbers 2, 9, and 
10, it is important that the new addition be designed and constructed so that the 
character -defining features of the historic building or buildings are not radically 
changed, obscured, damaged, or destroyed in the process of rehabilitation. Further, new 
additions should be compatible in terms of mass, materials, relationship of solids to voids 
and color; and the size and scale of the addition should be in proportion to the historic 
building, and attached if possible, to the rear or inconspicuous side. New designs may be 
contemporary or may be in the "style" of the historic building as ]ong as there is a clear 
distinction between the two and the new work does not appear to be part of the historic 
resource. 

Application : A pair of 4 story brick rowhouses was to be rehabilitated for use as an in- 
town hotel. The Federal style buildings were constructed in 1809 as part of a row of 
large residences, but shortly thereafter, they were converted for commercial use. In the 
1870's, the two adjacent buildings were modified and connected for use as an inn, and 
continued in that use until the 1970's. The two buildings, now identified as one structure, 
were recently listed in the National Register. 

The new owner wanted to reopen the historic building as a small in-town hotel, but the 
structure lacked certain features necessary for the successful operation of a modern 
hotel. The interior needed remodeling along with new elevators, restaurant facilities and 
additional rental rooms. The new owner proposed three small additions to accommodate 
these needs: a recessed rooftop shed dormer to house elevator equipment, and two small 
k story additions in the rear. While the rooftop addition would not be visible from the 
street, one of the rear additions would be highly visible as the property was located on a 
corner (see illus. 1). 

The original design proposal submitted to the State historic preservation officer showed 
the rear additions constructed in brick which replicated the brick details of the historic 
resource. In addition, the existing hip roof was expanded to cover the new rear 
additions. As a result, the new construction could not be differentiated from the historic 
building. 



83-051 

In reviewing the initial application, the State office made note of several important 
aspects of the project that would require redesign. As a Federal era design, the pair of 
town houses was distinguished by narrow, one room deep "T" shaped plans. The state felt 
that the infilling of this plan should not give the appearance of earlier mid-Georgian 
plans that were heavier in mass and proportion. As such, the State recommended that 
the new additions read as separate structures connected to the historic resource, thereby 
preserving the original sense of the Federal plan. In addition, the new construction 
should be attached to the historic building with a minimum of damage to historic fabric 
so that if, in the future, the additions were to be removed, the basic form and integrity 
of the historic structure would remain. 

The SHPO suggested that a contemporary design for the additions be considered, that 
the materials used provide a neutral backdrop for the historic resource, that the roofline 
of the additions be lowered so as not to damage the ornamental historic cornice, and that 
care be taken to minimize removal of historic fabric. In essence, the new rear additions 
should be treated as separate pavilions that would read as new construction in order to 
preserve the character -defining features of the historic resource. The owner was 
amenable to these suggestions and resubmitted his design (see illus. 2), which was then 
forwarded to the regional office with a recommendation for approval. 

In reviewing the proposal, the regional office agreed with the State on the need to 
clearly differentiate the new construction from the historic resource through the use of 
materials and setback connection details, while achieving compatibility in terms of scale, 
proportion, and location. A modern flush metal panel system was selected for the 
exterior sheathing of the new construction to act as a neutral backdrop to the carefully 
restored historic brickwork. The use of glazed panels recessed between the historic 
masonry and the new addition would allow the distinct feature of the Federal plan to be 
exposed. In addition, much of the original rear walls of the historic structure would 
remain exposed with the windows in place as part of the new construction. This would 
reduce the loss of historic fabric while leaving clear evidence of the connection between 
the original and new construction (see illus. 3). 

On the exterior, the new additions would reflect the scale, massing, and proportions of 
the historic building without replicating the original detailing. The placement of the 
window and door openings on the exterior of the new pavilions would match the scale and 
proportion of the historic facade, but the detailing would be executed in a modern 
fashion. The use of a separate hipped roof for the pavilion additions would maintain the 
scale of the historic rowhouses and the neighborhood (see illus. 4). 

The regional office approved the proposed rehabilitation as the existing historic resource 
was being carefully preserved and the new additions were compatible with the historic 
character of the property. 

Prepared by: Sharon C. Park, AIA, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of the 
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique 
facts and circumstances of each particular case. 



^*>^c**.r «u«* — , 




83-051 



Illustration //I. Site Plan 
The proposed two rear additions would 
change the plan from a "T" shape to a 
deep rectangle. In order to preserve the 
characteristic proportions of the Federal 
era, circa 1809, plan, it was determined 
that the new additions read as separate 
structures and not as a continuation of 
the historic structure. 




3 



; * - ,^ «■ -Am *■ 







Illustration #2. PERSPECTIVE VIEW. The revised design treated the rear addition 
as a modern pavilion to clearly differentiate it from the historic structure. 



83-051 




(i 



Illustration //3. TYPICAL FLOOR PLAN. 
The proposed infill plan (shaded) would 
respect the historic materials by leaving the 
original rear walls exposed within the new 
addition. The existing window and door 
openings would be left in place, as much as 
possible. In addition, recessed panels would 
be used as a connector infill between the 
original building and the additions in order t< 
clearly differentiate the new construction 
from the historic structure. 



Illustration #4. ELEVATION 
The new 4 story addition visible from 
the street would be compatible in 
scale and proportion with the historic 
structure. The pattern of window and 
door openings in the new addition 
would reflect the rhythm in the 
historic facade. The use of a modern 
panel system, as opposed to detailed 
brickwork, would clearly separate the 
new construction from the historic 
resource. The use of a separate 
hipped roof for the addition would 
retain the scale of the property and 
would eliminate damage to the 
historic roof and cornice. 




< 



t 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



the Secretary of the Interior's 

ass . , — =-/ — ^ i i mm ii 



Standards tor Rehabilitation 



Number: S3-032 



Applicable Standard: 2. Retention of Architectural Character (conformance) 

6. Repair /Replacement of Deteriorated or Missing 

Architectural Features Based on Historical Evidence 
(conformance) 

Subject : COMPATIBLE, NON-MATCHING REPLACEMENT WINDOW SASH 

Issue: Windows in historic buildings— both the openings and the actual sash that fill the 
openings— can play an important role in defining historic character. Where window 
openings or window sash are distinguishing features of the historic building (especially on 
primary facades), building owners should strive to retain and repair them, in accordance 
with Standard 6. If, after careful investigation, the window frames and sash are found to 
be so deteriorated that they must be replaced, then replacement windows should match 
the historic windows as closely as possible, also in accordance with Standard 6 and the 
rehabilitation guidelines. Unfortunately, owners often replace historic windows with 
incomDatible windows as part of a rehabilitation project, resulting in denial of 
certification. In rare cases, non-matching replacement sash may be acceptable where 
the historic window sash are not considered essential in defining the overall character of 
the building. This usually occurs on buildings with richly ornamented facades where 
there are numerous architectural features and details that add a high degree of 
articulation to the building, and which are the major determinants of its historic 
character. It should be emphasized, however, that this is the exception, rather than the 
rule, and that violation of Standard 6 will usually result in certification denial. 

Application: A 10-story, 190^ classical revival commercial building in a proposed 
historic district was rehabilitated as housing for the elderly. The primary facade of 
rusticated concrete and limestone was richly decorated with brackets, cartouches, and 
pediments. The project work included replacement of all the historic window sash. 
(Fortunately, no new window openings were made, nor was the proportion or size of the 
window openings changed.) The original wooden window sash were replaced with double- 
glazed metal units. The original sash were divided at midpoint by a horizontal meeting 
rail; this division was repeated with the metal replacement sash, but the meeting rail was 
thinner, and was placed on the lower third of the sash. On the seventh floor, a pair of 
tripartite arched windows were further altered by replacement with fixed single pane 
glazing in the side lights. Although a horizontal division of the sash was maintained, the 
replacements altered the historic pane configuration and meeting rail dimensions. With 
the concurrence of the SHPO, the NPS regional office denied certification. This 
decision was explained in the denial letter to the owner: 

The result of all these window alterations has had a detrimental effect on 
the historic appearance of the building. When it is necessary to replace 
existing historic windows in the course of rehabilitation, the "Standards" 
for this program require that the replacement windows match the visual 
qualities of the historic windows. 



83-052 

In requesting an appeal, the owners contended that the new windows "caused no 
noticeable change in the building's appearance from any angle or distance." The owners 
also submitted additional photographs of the primary facade taken before and after the 
window installation. 

After inspecting the property and reviewing the additional information submitted by the 
owner, the appeals officer overruled the original decision. Central to the reversal was 
the appeals officer's determination that the historic windows were not critical in defining 
the historic character of this particular building, and the replacement windows were 
compatible. The appeals officer stated in the notification letter: 

The historic character of this building is primarily determined by its form 
and by the richness and scale of the architectural features, including the 
split pediments, rusticated columns and voussoirs; carved garlands, 
brackets, sculptured keystones, tabernacle frames and cartouches. I do 
not consider the windows to be an essential character -giving element in 
this particular building. Even though the proportions of the pane openings 
and rail dimensions have been altered, the relationship of solid wall to 
windows openings was preserved in the rehabilitation process; in this 
particular case, I feel that the replacement windows minimally meet the 
Secretary's "Standards for Rehabilitation" and the overall rehabilitation is 
consistent with the historic character of the building. I would not expect 
to make this decision where similar window treatments were proposed on 
a building less ornate than this one. 

Prepared by: Jean Travers, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of the 
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique 
facts and circumstances of each particular case. 



83-052 




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'reservation Assistance Division jjjgj [ JIOlH I v-j 



Jational Park Service 

J.S. Department of the Interior 

Vashington, D.C. 



t fie Secreta r y of the Interior's 

"^ ^^_ ■ — w ■ ■■■ -". ■ 



"Standards toTRehabilitation 



Number: 84-053 

Applicable Standards: 1. Compatible New Use (nonconformance) 

2. Retention of Distinguishing Architectural 
Character (conformance; nonconformance) 

4. Retention of Significant Later 
Alterations/ Additions (nonconformance) 

5. Sensitive Treatment of Distinctive Features and 
Craftsmanship (conformance; nonconformance) 

Subject: REHABILITATING HISTORIC STOREFRONTS FOR NON-COMMERCIAL USE 

Issue: The historic character of a commercial structure is often jeopardized when a 
building is rehabilitated for residential or office use. The owner, therefore, must first 
consider Standard 1 of the Secretary of the Interior's "Standards for Rehabilitation", 
which addresses the issue of compatible new use when determining the nature of a 
rehabilitation project. If a commercial building is to be used for residential purposes, 
several factors must be considered in order to preserve its historic character. Because 
the open quality of most storefronts is not always compatible with the greater privacy 
and security required for new uses, owners often propose designs that involve the 
alteration or removal of historic materials and features. In storefronts, such features 
may include large expanses of glass, transom lights, cast iron surrounds, kick plates, 
elaborate cornices, and special entrance conditions. Collectively, these elements can be 
important in defining the unique character of a commercial building and should thus be 
retained in the process of rehabilitation. 

According to Standard 2 of the Secretary of the Interior's "Standards for Rehabilitation," 
"the distinguishing original qualities or character of a building, structure, or site and its 
environment shall not be destroyed. The removal or alteration of any historic material 
or distinctive architectural features should be avoided when possible." In order to 
comply with the Secretary's Standards, it is necessary to assess the feasibility of 
residential or office use on the main floor and the need to preserve the historic 
storefront character of the building. To properly address preservation issues and weigh 
them against the demands of contemporary re-use, rehabilitation projects require 
innovative design solutions which are sensitive to historic materials and features. 
Radical alterations to the storefront of a historic commercial structure will result in 
diminution of the building's historic character and ultimately in denial of certification 
for tax benefits. 

Application: A mid-nineteenth century corner grocery store and residence was converted 
to a two-unit residential building. Located in a historic district of mixed commercial and 
residential use, the building exhibited the scale, detail and simple architectural design 
characteristic of the time period and area in which it was constructed (see illus. 1 and 
2). In preserving the existing storefront and diagonal entrance, the owner installed new 
plate glass in the existing openings and transoms, and replaced the recently constructed 
brick infill below the plate glass windows with wooden panels (see illus. 3 and 4). The 
cornice, often a significant architectural element in storefront design, was also repaired 
and repainted. Important interior features such as a pressed tin ceiling and pine 



84-053 

fireplace mantel were restored. The completed design maintains the commercial 
character of the building, yet, with the inserted wood panels at the base and the possible 
addition of appropriate curtains or shutters behind the plate glass, it does not sacrifice 
the privacy of the residents. The project is, therefore, in conformance with the 
Secretary's Standards and was approved as a certified rehabilitation by the National Park 
Service. 

A second project involved the conversion of an early nineteenth-century brick Federal 
style townhouse into law offices. Originally a residential structure, the building had been 
used for commercial purposes as early as 1902 and had acquired a new entrance and wood 
and glass storefront on the ground floor (see illus. 5). Because other structures along the 
street had also been adapted for commercial use at an early date, this was seen as a 
significant development in the evolution of the district. The area is currently comprised 
of buildings which are primarily commercial at street level and residential above. 

Rehabilitating the building, which had been substantially damaged by fire, involved 
completely removing the existing storefront and entrance and replacing the historic 
opening with brick infill and residential-scale fenestration which replicated that on the 
upper floors (see illus. 6). This treatment violates numbers 2, k and 5 of the Secretary's 
Standards. By continuing the facade treatment of the upper floors on the street level, 
the commercial character of the building was lost and the continuity of the streetscape 
interrupted. The impact of inserting a building with residential character was dramatic 
because the structure is one of a continuous row of buildings, which, although not built 
together, had acquired significance as commercial structures and read as a consistent 
portion of the district. The project was denied certification on the basis that the 
changes to the front facade, especially the loss of the building's storefront character, 
were not in keeping with the Secretary's Standards. In an appeal of this denial new 
information was presented which indicated that the date of construction of the existing 
storefront was recent (approximately 1950) and that the storefront had suffered 
extensive fire damage. While the denial was reversed because of new information and 
because, in lieu of the damaged storefront, the owners had attempted to return the 
building to its original residential appearance, the Chief Appeals Officer took this 
opportunity to express his conviction that the commercial character of this part of the 
district reflected changes to the area over time and, where possible, should be preserved. 

A third rehabilitation of a two-story mid-nineteenth century commercial structure in an 
urban residential neighborhood involved the retention of a corner entrance and projecting 
display cases. To adapt the building to residential use, wood lattice in a contemporary 
motif was applied to the inside of the projecting bays (see illus. 7). Although not a Tax 
Act project, this unique, yet reversible, design solution increases privacy and security 
from the street while preserving the historic fabric and commercial character of the 
building. By respecting the building's original appearance, its compatibility with 
neighboring structures is maintained. 

Prepared by; Martha L. Werenfels, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 




84-053 



Example One 

1. and 2. Before rehabilitation. The 
corner grocery store had its original 
diagonal entrance and flanking plate 
glass windows. Although the storefront 
remained intact, the base had been filled 
with brick and the plate glass boarded 
over. 




84-053 




Example Three. 



7. Wood lattice installed inside the display windows increases 
privacy from the street without sacrificing the commercial 
character of the building. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



1 Interpreting 



the Secreta r y ot the Interior's 



"Standards tor Rehabilitation 



Number: 84-054 



Applicable Standards: 2. Preserving the Distinguishing Character of 

a Building (nonconformance) 

3. Recognition of Historic Period 
(nonconformance) 

4. Retention of Significant Later 
Alterations/ Additions (nonconformance) 

5. Sensitive Treatment of Distinctive Features 
and Craftsmanship (nonconformance) 

6. Repair/replacement of Deteriorated or 
Missing Features Based on Historical 
Evidence (nonconformance) 



Subject: REPLACING REPAIRABLE HISTORIC INTERIOR/EXTERIOR FEATURES 
AND MATERIAL 

Issue: "Rehabilitation," as defined in 36 CFR 67.2 assumes that some alteration is 
necessary to accommodate a new use; at the same time, the definition makes clear 
the requirement that those portions or features of the property which are "significant 
to its historic, architectural, and cultural values must be preserved." In order to meet 
this preservation requirement and be certified for tax benefits, features and materials 
of both the interior and the exterior of a building that are important—or character- 
defining— should (1) be identified in the planning stage; and (2) be retained and 
repaired in the work stage so that alterations necessary for the new use do not result 
in their loss. 

It is particularly important to note that preserving exterior features does not mean 
that, as a trade-off, interior material and features can be removed; similarly, 
repairing and preserving interior features does not mean that exterior materials and 
features can be removed. When either interior or exterior materials and features that 
are important in defining the building's historic charcter are removed, the 
rehabilitation may violate Standard 2, 3, 4, 5, or 6 and, in consequence, be denied 
certification for tax benefits. 

Application: An 1894 townhouse located in a historic district in the midwest exhibits 
on the exterior the simple architectural details characteristic of late-nineteenth 
century townhouses built in the area. The three-story, three-bay residence has 
modestly detailed brickwork, a recessed entrance with an ionic column supporting a 
first floor entablature and decorative lintels over second floor windows (see illus. 1). 
This simple detailing is also present on the interior, where a considerable amount of 
historic material, including millwork, mantels, doors, and moldings contributes to the 
character of the building (see illus. 2). The floor plan, with side entrance and stair 
hall, also has an unusual diagonal arrangement of the mantel and partitions in the 
parlor (see illus. 3). 



84-054 

In order to convert the residence into four modern apartment units, both exterior and 
interior work was necessary. The owner's rehabilitation proposal for the townhouse 
exterior included cleaning the masonry with low-pressure water; limited tuckpointing; 
replacing a severely deteriorated cornice with one which would match the existing in 
material and detailing; replacing a later front door with one milled to the dimensions 
of the original; and replacing unrepairable window sash with new sash, reusing the 
historic wood frames. All of this exterior work was considered to be in conformance 
with the Secretary's Standards. 

Interior demolition had already begun when the project was reviewed by the National 
Park Service. This work included removal of historic material and features which the 
owner assessed as "unusable." The owner's proposed floor plan for the apartments (see 
illus. 4) required removal of existing partitions; subdivision of the front parlor in order 
to maximize rentable bedroom space; and relocation of the living area to the former 
historic entrance and stair hall space. Substantial rearrangement of rooms throughout 
the building resulted in removal of additional partitions and corner fireplaces. Door 
and window trim, as well as baseboards and doors, were also removed. The regional 
office of the National Park Service felt that the interior materials, features, and 
spaces were important in defining the historic character, and should have been 
retained and repaired to the greatest extent possible. In consequence, the project was 
found to be in violation of Standards 2, 5, and 6 and was denied certification for tax 
benefits. 

In appealing the denial, the owner stated that some of the historic materials and 
features had been severely deteriorated and needed to be replaced; and that still 
others were missing entirely. Based on his assessment, all existing historic materials 
and features were removed and a contemporary looking interior— considered by the 
owner to be a more marketable— was constructed. 

Photographic documentation presented at the appeal, however, indicated that the 
historic materials and features could have been repaired and only needed to be 
replaced in part with new material. It was the opinion of the Chief Appeals Officer 
that, together with the distinguishing spatial arrangement, interior materials and 
features should have been preserved in the process of rehabilitation. 

The owner then expressed a willingness to re-install portions of the historic interior 
material which had not been severely damaged in the removal process and had 
subsequently been stored; and to reconstruct the interior partitions and missing 
historic features using all new materials. However, due to the extensive removal of 
historic materials and features that should have been retained and repaired initially, 
this proposal was determined to be in violation of Standard 6. Once material is 
removed under such conditions, the loss is considered irretrievable; it cannot be 
remedied through reconstruction. The limited re-installation proposed in this case was 
determined not to constitute adequate preservation of the resource. It should also be 
noted that acceptable preservation work on the exterior, in conformance with the 
Standards, was not considered a mitigating factor because aU work must be in 
conformance with the Standards for certification purposes. 



84-054 

Application; A second rehabilitation in the southeast involved a three-story wood 
frame house which was built ca. 1830 and displays Federal style features, including 
fireplaces, trim and doors. Changes had taken place on the exterior of the house 
ca. 1910, the most major of which was the addition of a large Victorian front porch 
extending across the front facade and wrapping around two sides (see illus. 5). The 
porch was characterized by columns resting on brick piers, turned ballusters and a 
decorative central pediment. At the time of the porch construction a lean-to addition 
was also built on the rear of the building and a bathroom was installed on the third 
floor. 

The intent of the rehabilitation work on the residence was to restore the building to 
its original 1830s appearance— the rationale for such work being largely predicated on 
the owner's assessment of the 1910 features. Because the porch was determined by the 
owner to be severely deteriorated and thus unrepairable, he felt preservation would 
require a prohibitively expensive dismantling and reconstruction of the piers, as well 
as total replacement of the roof (see illus. 6). As a result of this assessment, the 
porch was demolished. New front stairs and a covered stoop were then constructed on 
the primary facade to its 1830's appearance (see illus. 7). Interior work— including 
opening up of original fireplaces, removal of later inappropriate panelling, and repairs 
and repainting of doors and door trim— was also undertaken and completed as part of 
the project. 

When the project was reviewed by the State Historic Preservation Office, initial 
concern was expressed over potential violation of Standard 4 in the exterior 
demolition work, and, in a final review by the region, the work was subsequently 
denied for violation of Standards 2, 4, 5, and 6. According to a letter from the 
regional office of the National Park Service, "The Victorian porch was distinctive in 
terms of its large size and style. ..and had gained significance in its own right; thus, its 
removal resulted in the loss of an important feature attesting to both the stylistic and 
physical evolution of the structure." 

Finally, the Region agreed with the State in the final review that the porch as it 
existed at the time of the rehabilitation was deteriorated, but that its condition did 
not warrant removal. Because it was a character-defining feature that should have 
been retained and repaired, its removal violated Standards 2, 4, 5, and 6. A secondary 
issue in the denial was that the design for the new entry was not based on either 
photographic or physical evidence and was, therefore, conjectural. This treatment 
violated Standard //3. 

Because the owner felt that "restoration" to its 1830's appearance was an appropriate 
treatment for the structure, he appealed the regional decision. In a final letter to the 
owner that sustained the region's decision, the Acting Appeals Officer wrote: 

The c. 1910 wrap-around porch, which was removed during the course of 
rehabilitation, was significant in determining the character of the 
building... Removal of the porch, with its decorative frieze, classical columns 



84-054 



and turned ballusters, constitutes a loss of an important character-defining 
feature. ..While it is my understanding that work on the interior was well- 
executed, it cannot compensate for loss of a major character-defining 
element. 



Prepared by ; Kay D. Weeks and Martha L. Werenfels 



These bulletins are issued to explain preservation project decisions made by the U. S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



84-054 




1. The townhouse, with its simple detailing, pictured 
before rehabilitation. The owner's proposal for 
exterior work was considered to be in conformance 
with the Secretary's Standards. 





2. Modest interior detailing, such as window and 
baseboard trim, and diagonally placed mantels 
contribute to the historic character of the 1894 
townhouse and thus should have been preserved to the 
greatest extent possible. 



84-054 




E-XI5TIUCJ TLOO'fc PLAM 

3. A floor plan with side entrance and stair hall, and 
front parlor containing diagonally arranged partitions, 
chimney and mantel were identified as important in 
defining the historic character. 




PR0P05tD TL00R PLAM 



k. Interior work involved demolition of existing 
partitions as well as relocation of the living area to 
the historic entrance and stair hall space (see illus. 
3). The rearrangement of rooms led to removal of 
corner mantels, baseboards, and door and window trim 
(see illus. 2). Because the character-defining interior 
spaces, features, and materials were not sufficiently 
preserved, the entire project failed to meet the 
Standards, despite qualifying exterior work. 



M-Q5k 



I 





An 1S30 structure with its large 1910 wrap-around 
ch characterized by columns resting on brick piers, 
ighly decorative central pediment and turned 
lusters. The porch was in a deteriorated, but still 
airable, condition prior to rehabilitation work. 



6. A detail of the 1910 porch shows structural 
problems that need to be corrected. The owner 
assessed the 1910 front porch as unrepairable, which 
led to its removal. 



) 




7. The replacement front porch—conjectural in 
design— was constructed after demolition of the 
historic porch. NPS concluded that because the 1910 
porch was an important character-defining feature and 
was repairable, it should have been retained. The 
project was denied certification of rehabilitation for 
tax benefits. 



echnical Preservation Services I Ui^M^K/^+Ir^ 
reservation Assistance Division UGlD! 611 lQ 

lationa! Park Service . - LT v 2 



National Park Service 

J.S. Department of the Interior 

Washington, D.C. 



the Secretar y ot the IntenoTs 



Standards tor Rehabilitation 



Number: 8^-055 

Applicable Standards: 2. Preserving the Distinguishing Character of 

a Building (nonconformance) 

3. Recognition of Historic Period 
(nonconformance) 

6. Repair/Replacement of Deteriorated or 

Missing Features Based on Historical 
Evidence (nonconformance) 

Subject: REPLACING HISTORIC MATERIALS/FEATURES WITH NEW MATERIAL 
TO CREATE AN "IMPROVED" APPEARANCE 

Issue: As stated in 36 CFR 67.2 the treatment "rehabilitation" assumes that at least 
some repair or alteration of the historic building will need to take place in order to 
provide for an efficient contemporary use; however, these repairs and alterations must 
not damage or destroy the materials and features— including their finishes—that are 
important in defining the building's historic character. In terms of specific project 
work, preservation of the building and its historic character is based on the assumption 
that (1) the historic materials and features and their unique craftsmanship are of 
primary importance and that (2), in consequence, they will be retained, protected, and 
repaired in the process of rehabilitation to the greatest extent possible, not removed 
and replaced with materials and features which appear to be historic, but which are— 
in fact— new. 

Sometimes an owner or developer will fail to identify character -de fining materials or 
features in the planning stage and, in consequence, will remove or alter them so that 
the historic character of the building is compromised. More often, however, 
character-defining materials and features on the exterior or the interior are 
adequately identified but, in a mistaken effort to make the historic building look like 
new or to have an improved or uniform appearance, they are removed and replaced 
with new material. In other words, rather than retaining or repairing the historic 
material and features, an owner or developer will remove them— perhaps believing 
they are unrepairable or that repair costs are too high— then use new materials to 
create "historic appearing " features, or, alternatively, to create a contemporary 
look. In either case, the justification is often that the new product looks even better 
than the historic material and will be more visually appealing for re-use purposes. 

Such removal and replacement of historic materials will violate Standards 2, 3, and 
6. A determination to remove and replace character-defining materials and features 
must be based on severe damage or deterioration, as determined by a structural 
engineer or other qualified professional. Then, even if well-defined circumstances 
exist justifying replacement of individual features for visual reasons— or a loadbearing 
wall for structural reasons— it is critical that so much new material is not introduced 
that a historic building becomes essentially new construction. 



84-055 

Application; A ca. 1870 stone Gothic Revival structure (see illus. 1) was being 
rehabilitated for re-use as an office building. A 1967 "modernization" of the building's 
facade for retail use had involved installation of a stucco false front on the upper 
level of the building. When the false front was subsequently removed as part of the 
new work, the owner found that the castellated stone at the top of the building had 
been removed; the historic decorative bands had been chipped away to permit 
installation of the stucco work; the window sills and jambs were damaged; and several 
holes had been bored into the stone to anchor the false front. Stone on the ground 
level of the building had been removed as the result of a 1950s installation of an 
aluminum and glass entry and merchandise and display area (see illus. 2 and 3). 

Based on his evaluation of the overall damages to the stone as a result of the 
combined alterations, the owner concluded that the entire facade was essentially 
beyond repair and that partial replacement of the historic material would not be 
possible without leaving a splotchy, uneven facade— an appearance he felt was 
unacceptable. The report specifically cited the unavailability of matching limestone, 
potential structural consequences of replacing only the damaged stone, and the high 
cost of repair over replacement. As a result of this assessment, the owners elected to 
demolish both damaged and intact historic limestone from the primary facade by 
cutting it back to a depth of 5 inches, then re-build the facade with an all new stone 
veneer in order to achieve an even, uniform appearance (see illus. 4). 

When the Part II application was reviewed by the State, concerns were expressed 
about the removal of what they assessed— as a result of a site inspection— to be a 
largely intact upper level that could have been repaired; and the subsequent 
demolition of the entire character-defining facade and reconstruction with all new 
material. Considered a precedent-setting project by the region, application materials 
were forwarded to the Associate Director, National Register Programs, for an opinion 
before a final decision was reached. 

In a memo to the regional office, the Associate Director stated: 

It is our understanding that there are no significant features or spaces on the 
interior and that the facade was the sole "character-defining" feature of the 
structure. Because so little significant historic material remained, it became 
all the more important to retain what had survived to the present. While the 
party and rear walls and floor systems remain intact, retention of these 
components does not constitute adequate preservation of the resource for 
Federal tax benefits. The integrity of the individual architectural features 
and spaces has been irretrievably lost, as a result of other changes over the 
years and, finally, as a result of this most recent rehabilitation. 

Prepared by: Kay D. Weeks 



These bulletins are issued to explain preservation project decisions made by the U. S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



> 



8<f-055 



ff> 










WMj ^smM *- • 







57?! 



X A A A A , 






uaaaafArygy-, 




k~ ^ /^k 




J? 




| is historic photograph shows the 1870s building 2. A 1967 storefront alteration involved installation of 



ntact limestone and distinguishing Gothic 
al detailing. 



a stucco false front on the upper levels; stone at the 
ground level had been removed as the result of the 
installation of an aluminum and glass entry in the 
1950s. 



84-055 



» 




h I f i 

•Hi 

I P M 1 





3. When the 1967 storefront was removed, the owner 
assessed overall damages to the upper and lower levels 
and felt total replacement of the limestone facade was 
necessary to restore the historic appearance. 



4. This photograph shows a totally reconstructed 
facade using all new material. NPS recommende 
denial of the project for tax benefits because it v 
determined that the damaged upper level could h. 
been repaired. An unacceptable loss of historic 
material on a significant facade was specifically 
in the denial letter. 



ii 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



the Secretary of the Interior's 



Standards tor Rehabilitation 



Number: 8<f-056 

Applicable Standards: 2. Preserving the distinguishing character of a 

building (conformance) 
3. Recognition of Historic Period 

(conformance) 
6. Repair/replacement of Deteriorated or 

Missing Features based on Historical 

Evidence (conformance) 



Subject: REPLACING SEVERELY DETERIORATED HISTORIC MATERIALS 

Issue: Although maximum retention of historic material is always the primary goal in 
rehabilitation projects, building features may be so severely deteriorated that 
replacement with new material is required, either for visual or for structural reasons— 
or both. Such replacement may be limited to several bricks, wood window sash, or 
brackets of a cornice; or may involve an entire loadbearing wall or walls. 

In the latter situation, when extensive replacement of historic material has been 
recommended by a structural engineer or other qualified professional— even if it is to 
be replaced with matching new material— it is important that so much new material is 
not introduced that a formerly historic building becomes essentially new 
construction. In this regard, replacing a structurally unsound wail on a side or rear 
elevation is usually less critical than replacing deteriorated features on a primary 
elevation; similarly, replacing extensively damaged interior material and features on 
upper floors may be less critical than removing and replacing significant material and 
features in highly visible first-floor spaces. It should be remembered, however, that 
even when features and material which are secondary in defining the character of the 
building are extensively replaced, the cumulative effect may involve such a high 
degree of loss that, in consequence, the project will violate Standards 2 and 3. When 
extensive loss of historic material occurs— even if severe deterioration or damage is 
present and seems to warrant extensive replacement— a project can be denied 
certification because the "historic resource" is no longer historic. 

Application: An 1860s rusticated ashlar brownstone commercial building, altered in 
1880 with the addition of a flush ashlar brownstone facade on the west, was purchased 
for rehabilitation for office use (see illus. 1). The building had been derelict and 
vandalized for several years— in addition to the total lack of maintenance— and, as a 
result, was severely damaged and deteriorated. Within the three exterior walls (south, 
west, and north), which consist of l^inch thick loadbearing masonry of two wythes of 
brick faced with brownstone, the mortar was failing between the brick and the stone. 
The brownstone was spalling on both the north and south walls, with the condition 
much worse on the north (see illus. 2 and 3). The building had been painted in the past, 
possibly in an effort to stop water penetration. On the interior, the majority of the 
distinguishing architectural detailing had been removed as a result of deterioration, 



84-056 

vandalism, and inappropriate earlier work. A cast iron and marble stairway between 
the first and second floors and two cast-iron columns with ornate capitals on the first 
floor were still in place. The floor structure and flooring were intact, but damaged, 
and historic window trim and some sash remained. 

An initial structural assessment led to a proposal to rebuild the north and south 
walls. The structural engineer felt that the original construction technique— tying the 
interior brick to the facing brownstone with iron strap anchors— was inadequate. 
Further, the deficiency of the walls had been aggravated by water penetration into the 
cavity between the brick and the stone, which had caused the iron anchors to rust. 
The recommendation to rebuild both walls was based primarly on a few test holes 
bored in the walls for investigation of the condition of the materials, particularly the 
metal anchors; and on the fact that both walls were out-of-plumb by about two 
inches. However, because this proposal— along with planned interior alterations for 
modern office use— involved such a substantial loss of historic material, the National 
Park Service determined that if the project proceeded as proposed, the resulting 
building would be substantially new construction. Therefore, despite the seriously 
deteriorated condition of the materials, NPS found that the work, as proposed, would 
violate Standards 2, 3, and 6. 

Subsequently, two structural engineers sought ways to preserve more of the historic 
material. It was confirmed that the north and south walls were out-of-plumb. To 
ascertain the reason for the apparent structural problems, more holes were bored so 
that the condition of the walls could be thoroughly investigated. The findings were 
that the north wall had lost its loadbearing capacity because of the advanced 
deterioration of the stone, brick, and iron anchors; however, the engineers' solution 
was to rebuild the wall only from the second floor up rather than the entire wall as 
initially proposed. Since the materials were not salvageable, the replacement wall 
would be all new materials. Cast-stone over concrete block was selected as a 
compatible substitute material with the facing cast-stone to simulate the historic 
brownstone. The re-evaluation of the structural and preservation problems of the 
building led to the conclusion by the architect and engineer that the south wall could 
be retained in place with the use of stainless-steel pins tying cementitious patches to 
the sound brownstone beneath. The bulk of the patching would be at the beveled edges 
of the ashlar blocks where the worst erosion had occurred, leaving the majority of the 
historic material intact and visible. 

As opposed to the initial approach, this proposal was found to preserve considerably 
more historic material and was thus given preliminary approval; however, in approving 
the rehabilitation proposal for Federal tax incentives, the National Park Service 
expressed "serious concerns about the severe deterioration of the building." The 
certification letter further stated that the positive determination was based on the 
assessment "that the wooden floor and ceiling framing, the window trim on the 
exterior walls, and some window sash on the west wall.. .as well as the first floor 
columns and stair can be saved. It is possible that unforeseen problems, including 
additional loss of historic fabric, may jeopardize certification." 

During the rehabilitation, the building was sold. The new owner wanted to rebuild 
both the south wall (facing the main street) as well as the north wall (facing a side 
street) in order to avert the possibility of future structural problems and to achieve a 



84-056 

uniform appearance. When asked about amending the certification application to 
include this new work, the National Park Service referred to its earlier approval 
letter, stating that any further loss of historic material would result in denial of 
certification for the entire project. The owner consequently proceeded with the 
project as initially approved. 



Prepared by: Susan Dynes and Kay D. Weeks 



These bulletins are issued to explain preservation project decisions made by the U. S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



84-056 




1. This photograph of the west elevation shows the 
1880 addition of flush ashlar brownstone above the 
rough-cut brownstone of the first floor. Because the 
historic brownstone on this wall was basically sound, 
only repainting was required. 





2. The brownstone oi the south wall was not as 
deteriorated and could be retained in place and 
structurally strengthened by stainless steel pins 
tying cementitous patches to the sound stone 
beneath. Limiting the patching to the beveled 
edges of the stone blocks where the greatest 
amount of deterioration had occurred was 
considered a sensitive preservation solution 
because it left the historic material both intact 
and visible. 



3. Badly spalling brownstone on the north, and les: 
visible, wall was for the most part unsalvageable. 
Replacement walls were constructed from the sec< 
story up, a solution that assured maximum retentic 
historic material while making the building 
structurally sound for the new use. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpretin g 



ffjeTSecretarv of the Interior's 



Standards tor Rehabilitation 



Number:84-057 



Applicable Standards: 2. Retention of Distinguishing Architectural 

Character (nonconformance) 
6. Repair/Replacement of Deteriorated or 
Missing Architectural Features Based on 
Historical Evidence (nonconformance) 



Subject: INAPPROPRIATE REPLACEMENT WINDOWS 

Issue: A highly decorative window with an unusual shape, or glazing pattern, or color 
is most likely to be immediately identified as a character-defining feature of the 
historic building. It is far more difficult, however, to assess the importance of 
repeated windows on a facade, particularly if they are individually simple in design 
and material, such as the single light, double-hung sash commonly found in many 
vernacular late 19th and early 20th century buildings. Because rehabilitation projects 
frequently include proposals to upgrade or replace window sash or even replace entire 
windows, it is essential that both their contribution to the historic character and their 
physical condition be evaluated before specific repair or replacement work is 
undertaken. 

In the latter half of the 19th century, the use of standard size sheets of clear glass; 
the equal division of lights on both the top and bottom of double-hung windows; and 
the lack of muntins represented a window evolution that stemmed from an interaction 
of style changes and technological developments. In consequence, such simple double- 
hung (1/1) windows are often a distinguishing architectural feature of the building that 
should be identified, retained, and preserved in the process of upgrading or repairs 
within an overall rehabilitation project. A successful preservation solution, however, 
is contingent upon recognizing the design role of the windows in determining the 
historic character; then prescribing sensitive repair and upgrading techniques. 

If the historic windows are determined to be unrepairable, replacement windows need 
to be chosen with great care. Again, it is crucial that the role of the windows in 
determining the historic character be identified first—in other words, the relative 
importance of the size, shape, color, and detailing of the windows to the overall 
appearance of the building. After this initial assessment is made, various replacement 
units available from manufacturers can be evaluated to assure an acceptable 
replacement solution. Unfortunately, all too often an inappropriate approach is taken, 
that is, simple double-hung (1/1) windows are replaced with aluminum units without 
matching the trim detail, the width of the frames and sash, the location of the 
meeting rail, the reveal or setback of the window from the wall plane, the separate 
planes of the two sash, or the color or reflective qualities of the glass. In particular, 
the installation of inappropriately designed replacement windows in a relatively 
unornamented building can dramatically change the historic appearance of such a 
building and, as a result, violate Standards 2 and 6. 



84-057 

Application: A six-story residential/office building located in a historic district in a 
large northeastern city was recently rehabilitated. The work consisted of substantial 
alterations to the interior in its conversion to modern apartments; restoration of the 
front entrance; and the installation of replacement windows. Because there 
apparently were few remaining historic features on the interior, the historic character 
was primarly determined by its exterior— the materials, features, and finishes. For 
this reason, it was particularly important to preserve the historic appearance of the 
exterior to the maximum extent possible. 

Due to its prominent location at the end of a row of 19th century structures, this 
simple, but distinctively-detailed early 20th century building, had three highly visible 
facades. On each of these facades, the traditional equally-sized double-hung sash 
were important features, comprising almost half of the total wall area. Their 
windows' color, proportions, spacing, and frame details also helped to relate the 
building to the adjacent older properties (see illus. 1). 

Because the windows were determined by the owner to be unrepairable, they were 
removed and replacement units were selected and installed. The replacement windows 
had flat frames devoid of molding detail, a bronze-anodized finish, and a fixed upper 
and operable lower sash. Further, the location of the meeting rail was lowered— for 
ease of operation of the large sash— so that the lower sash was only 1/3 rather than 
1/2 the size of the historic window (see illus. 2). The owner also chose tinted glass 
which she felt was justified in order to lessen the visual impact of an adjacent 
elevated highway. 

When the regional office reviewed the work, they determined it violated Standards 2 
and 6. The denial letter stated: 

...The historic windows, with clear planes in a 1/L configuration 
contributed to the restrained character of the building. "Before" 
photographs show all of the 1/1 windows in place, and no 
documentation was provided with the Part 2 application to show 
that the exiting units could not have been repaired and retained. 
Had replacement proven necessary, the appropriate treatment 
would have been to use new units which matched the 
configuration, color, and other visual qualities of the historic 
windows. Instead, the replacement windows selected employ a 
lowered meeting rail (in a 2/3 to 1/3 configuration) and tinted 
glass. As a result, the replacement windows are incompatible 
with and detract from the historic character (see illus. 3). 

The owner appealed the region's decision on the basis that the replacement windows were 
necessary and the design did not detract from the historic character of the building. 
After careful consideration, the region's decision was sustained by the Chief Appeals 
Officer. In sustaining that decision, he added: 

Your major rehabilitation work on the facades of the building 
consisted of restoring the front entrance, and the window 
changes which are at issue. The lower floor with its different 
masonry treatment and decorative entrance certainly is more 
detailed than those above. Yet on the three intermediate floors- 
-which constitute the majority of the facade— the windows 
predominate, and they have now been changed through the 



84-057 

introduction of new metal frames and sash. Even on the top 
floor, the windows are an important feature even though the 
masonry has more decorative detail. You sought to justify the 
change in the appearance of the windows based on the 
desirability of tinted glass from an interior perspective and the 
wish for an easy-to-operate sash. While I would agree with you 
that the smaller sash may require less effort to operate, you 
could have found commercially available windows that would 
have matched the appearance of the historic sash, as required by 
Standard 6, and that would have been easy to operate. 



Prepared by t Charles E. Fisher and Kay D. Weeks, TPS 



These bulletins are issued to explain preservation project decisions made by 
the U.S. Department of the Interior. The resulting determinations, based 
on the Secretary of the Interior's Standards for Rehabilitation, are not 
necessarily applicable beyond the unique facts and circumstances of each 
particular case. 



84-057 




1. This 20th century building served as a anchor at the end of the small 
historic district and had three highly visible facades. Note how the 
location, design, and even the color of the wooden sash and frames matched 
that of the adjacent older properties. 




2. This is a close-up view of the contemporary window units which were 
installed. They had flat framing detail, bronze-anodized finish, tinted 
glass, and a lowered meeting rail. 



3. Below is a comparison view of "before" and "after" rehabilitation which 
shows the impact of the window changes. While relocation of the meeting 
rail was the most pronounced alteration, the tinted glass, lack of trim 
around the frames, increased width of the anodized aluminum frames, and 
loss of other detail were cited in denial of the project for preservation tax 
benefits. 



84-057 





re ca ^ -.'--'---' '-"'.' Services 
r ese r .5" c r -5.3 ra.' ce 1 . s c 
arona ^a/v Sen /ice 
3 Decatmer: of fie intenor 
asfi ngjon, D.C. 



interpreting 



the Secretary of the Interior's 



"Standards tor Rehabilitation 



Applicable Standi- 



." ben (<M)53 

2. Retention [ ng f\rchitec1 

Chars':": er ' - or cof forn ar ce 
5. Sensitive Tre a t m e n t of Distinctive Feat «*es and 

Craftsmanshi] 
9. Compatible Conternporar. Desigr f or Ne«r 

Alterations Additions Nonconformance 



Subject : INAPPROPRIATE SIZE AND SCALE OF S'Ei EXTERIOR -DDITIC 
LOSS OF HISTORIC CHARACTER 



Issue : In the Secretary of the Interior's "Standards for Rehabiiitation. the Department 
of the Interior acknowledge-, that a new exterior additior to a historic building (sucr as a 
fire stair, service wing, or additional story) may be essentia] to returr the property to a 
state of utility for an efficient conte". po r a-y isej however, a: the same time, the 
cjmulative effect of the design and installation process s: anew addition musl r at 
radically change, damage, destroy, or obscure those "portions and feat u res '.:' the 
orooertv which are significant to its historic, architect ,-ai, or cultural val jes. ' (3€ CF 
67.2). 

Therefore, in evaluating the a p propriateness of a new addition, it is critical that the 
important character-defining materials, form, features, and detailing of the historic 
building be properly identified so that the- nr a) be protected and preserve':, "lis 
identification process will also make clear those "port i ons and features" of the historic 

property that are not important in defi~ ing the historic character ar.d may t'-us tr- 
easonably altered or added to in the course of rehabilitating for the new jse. 

because of the difficulty in designing sensitive new additions a": to clarif > *hat 
constitutes a compatible r e i addition, die NPS oas expanded its guidance .~ this a-ea 
(see pp. 56-57, "New Exterior Additions tc Historic Bjiidings .' t'-.e Revised Guidelines 
to the Standards for Rehabilitation [1983). The advice listed first i- the guidelines istc 
avoid constructing a new exterior addition altogether because :' the potential for 
altering and expandui g the historic form and thereby cfimir shing the historic character. 
Rather, it is reco — ended that services and : unctions recjired c • the ne* :se oe . ocacec 
in non-character -defining interior spaces. 3nlj after it is ce:ermined tt at .nterior 
spaces cannot be utilized, should a nen exterior addition be considered at alL Then, the 
new addition should be ces.gned so that its size and scaie are limited in o-cportion in 
relationship to the histo ric bui .o.-g— and located on an incc sp -..:.-. s.ce z: a -.sct-.c 
building to further assure that there ~ ... oe -: radical changes to the histo'.c : - a-.c 
appearance. 

The failure to recognize those qualities that aom pr i se a buildings historic character 
materials, form, features, and detailing as veil as relationship :: the site and the 

district) prior to designing and attaching a ne exterior addition :^ _ res ill in overall 
changes that are incur sistent vitli thehistoric character. In consequence, Star c a - -. 1 
or 9 may be violated. : _ js eopardizing project sertification. 



84-058 

Application; A small late 1920s Mission Revival building of brick construction with 
stucco finish is primarily distinguished on the main facade by a waved parapet cap and 
symmetrically placed openings (see illus. 1). In rehabilitating the building for use as law 
offices, interior and exterior work was undertaken, including replacement of damaged 
plastered walls, re-stuccoing of the brick, cleaning and painting of windows, and the 
construction of two new exterior additions. 

The first new addition consisted of enclosing existing stairs at one end of the facade for 
the clients' main entrance, as well as serving as handicapped access to a ground floor 
elevator. The second new addition was a non-functional matching wing wall at the other 
end of the facade which the developer felt would preserve the sense of symmetry which 
was so strong in the historic building (see illus. 2 and 3). 

After reviewing the Part II application, the State office recommended denial of the 
project, citing violation of Standards 5 and 9; the regional office, completing its review, 
concurred with the State's assessment. In a denial letter to the owner, the regional 
office stated: 

The new additions, consisting of the exterior stairs enclosure at one end of the 
facade and the wing wall at the other end, increase the length of the facade by 
at least one-third, thereby altering significantly its overall mass, scale, and 
proportional relationships. Further, these additions extend and expand on the 
symmetrical historic design of the facade in a way that lends to it a degree of 
expansiveness...not present in the simple design character of the structure's 
original design features. It is apparent that the attempt to match the color, 
texture, and detail of the original design and to continue its symmetry by 
extending the facade wall was motivated by a desire to preserve the historic 
character of the building. In effect, however, this matching new design is 
incompatible: it compounds the additions' negative visual impacts on the 
original design by making contemporary and historic portions of the building 
indistinguishable from one another. 

When the project was subsequently appealed, the Chief Appeals Officer sustained the 
regional office's decision that the new additions violated Standards 5 and 9, adding that 
"they also give the building a monumentality that, historically, it never possessed, thus 
changing its historic character." In consequence, the project also failed to conform to 
Standard 2. As part of the appeals process, the architect forwarded three drawings 
(schemes A, B, and C; see illus. 4, 5, and 6) for possible changes to the new additions to 
bring the project into conformance with the Standards and thus qualify for Federal 
historic preservation tax incentives. After reviewing all of the drawings, the Chief Ap- 
peals Officer concluded in his final letter to the owner: 

The only remedial action that can now be taken... would be to follow scheme 
"C": insert a wide expansion joint between the historic building facade and the 
new stair enclosure, demolish the new wing wall, lower the parapet on the stair 
tower by at least one foot, and paint the new addition a different color than 
the original facade. These actions would make the distinction between the old 



84-058 

and new construction clear; and would restore to the buildng its aspect of a 
modest, simplified Spanish Colonial Revival commercial structure. Demolition 
of the wing wall would allow one to view the continuous wavy cornice as it 
carries around the corner. If the final revised project fails to meet any of the 
above conditions, it will not meet the Standards and cannot be certified. 



Prepared by: Kay O. Weeks, TPS 



These bulletins are issued to explain preservation project decisions made by the U. S. 
Department of the Interior. The resulting determinations, based on the Secretary of the 
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique 
facts and circumstances of each particular case. 



84-058 




1. This drawing points out the historic form of a small-scale Spanish Colonial Revival 
building with a waved parapet cap and symmetrical window and door openings. 




84-058 



2. This view of the southeast corner of the primary elevation shows the new addition 
that enclosed an existing stair. The addition extends from the termination of the historic 
building, which is defined by the waved parapet cap. 




3. This view of the northeast corner of the primary elevation shows the added wing wall 
that was built to visually balance the new addition on the southeast corner. Again, the 
addition extends from the end of the historic building, as defined by the waved parapet 
cap. Both additions increased the total length of the historic building by one-third and 
made indistinguishable what was historic and what was new construction. 




4. Scheme "A" was proposed by the developer to make the project meet the Standards. 
This change in the design would simply have provided expansion joints to show the 
difference between the historic buildng and the new additions. The proposal was 
rejected. 




5. Scheme "B" was also offered by the developer as a means of making the project meet 
the Standards. Part of this design change was acceptable—the lowered parapet on the 
stair enclosure. The total scheme was rejected, however, because the nonfunctional 
northeast wing wall, even though differentiated in height, still unnecessarily expanded 
the historic form of the building. It also created a symmetry at a scale that never 
existed historically. 



Z*i..'x,\At 









1 




6. Scheme "C" represents those changes to the design that would have to be made to 
bring the project into conformance with the Standards. The Chief Appeals Officer 
specifically listed as requirements for certification a widened expansion joint; demolition 
of the northeast corner wing wall; lowering the parapet on the stair tower; and further 
distinguishing the new addition from the historic facade by use of a different paint color. 



rechnical Preservation Services 
Reservation Assistance Division 
National Park Service 
J.S. Department of the Interior 
Washington, D.C. 



Interpretin g 



thlTSecretarv ot the Interior's 



"Standards tor Rehabilitation 



Number: 84-059 



Applicable Standards: 2. Retention of Distinguishing Architectural 

Character (nonconformance) 

5. Sensitive Treatment of Distinctive Features and 
Craftsmanship (nonconformance) 

6. Repair/Replacement of Deteriorated or Missing 
Features Based on Historical Evidence 
(nonconf orm ance) 



Subject : REPLACING A SIGNIFICANT INTERIOR FEATURE TO MEET HEALTH AND 
SAFETY CODE REQUIREMENTS 

Issue : To comply with health and safety codes in rehabilitation projects, the Revised 
Guidelines to the Secretary of the Interior's "Standards for Rehabilitation" first 
recommendation to owners and developers is to work with local code officials to 
investigate variances available under some codes or to devise creative and safe 
alternatives so that alterations and additions to historic buildings can be avoided 
completely, if possible. Because such variances or alternatives may not always be 
feasible, owners and developers are next advised to identify significant spaces, features, 
and finishes, so that they can be preserved in the process of successfully meeting code 
requirements (such as providing barrier-free access, upgrading historic stairways or 
elevators, or installing fire suppression systems). 

While it is understood that owners must often undertake work necessary to meet health 
and safety code, the Department of the Interior— by law— cannot approve rehabilitation 
projects if significant interior spaces, features, or finishes are lost as a result of such 
code-required work and, in consequence, the rehabilitation is not consistent with the 
historic character of the building. In reviewing an overall project, it is thus critical that 
administrators evaluate work proposals to assure that significant interior features are 
properly identified so that they may be protected and preserved in the process of 
meeting health and safety code requirements. Where a conflict exists between code 
requirements and the Secretary of the Interior's "Standards for Rehabilitation", it should 
be noted that "...The Secretary of the Interior's Standards take precedence over other 
regulations and codes in determining whether the historic character of the building is 
preserved in the process of rehabilitation and should be certified." 36 CFR 67.7(d). 

Application: An early 20th century commercial building was being rehabilitated for use 
as medical offices (see illus. 1) As the result of an inspection by a structural engineer to 
assure compliance with State health and safety codes, proposed rehabilitation work 
involved removal of a historic ornamental iron cage-type elevator that was manually 
operated (see illus. 2) and replacement with a modern elevator (see illus. 3) featuring 
automatic pushbutton operation. (The ANSI building code specifically requires an 
enclosed cab and hollow metal shaft doors.) Additional proposed work included removal 
of the ground floor elevator doors; removal of one set of the existing west-side elevator 
doors on floors #3 through //7; and the subsequent blocking of access to the elevator on 
that side due to limited passenger use after rehabilitation (see illus. k and 5). 



84-059 

When the project was initially reviewed by the S.H.P.O, recommendation for 
certification was made because it was felt that loss of the elevator —although 
unfortunate— did not constitute a radical change to the building's interior. However, 
when the National Park Service evaluated the proposed work that principally involved 
removal of the historic elevator and replacement with a modern elevator to meet code, a 
final determination was made that such removal of a significant interior feature violated 
Standards 2, 5, and 6. The denial letter to the owner stated: 

The elevator with its highly elaborate iron grillwork and the decoratively 
molded elevator doors in the lobby is a significant historic feature which 
contributes to the historic character of this early twentieth century 
commercial building. The features of the elevator, particularly the decorative 
cab and the lobby doors are historically significant elements which should be 
preserved. Your rehabilitation. ..will lead to the loss of a significant feature of 
the building, in violation of the Standards for Rehabilitation, and the 
rehabilitation will not be consistent with the historic character of the 
building. For purposes of the historic preservation tax incentives, the 
Standards for Rehabilitation take precedence over other regulations and codes 
in determining whether the historic character of the building is preserved in 
the process of rehabilitation and should be certified (36 CFR 67.7(d). 

The denial was subsequently appealed and, in spite of the owner's referral to ANSI codes 
requiring enclosure of the elevator, the NPS decision was sustained by the Chief Appeals 
Officer, who reiterated in the letter to the owner, "...since a rehabilitation must 
preserve the historic character of a property to be certified, I have determined that this 
project is not consistent with the historic character of the building and does not meet the 
"Standards for Rehabilitation." In the same letter— in order to achieve a certifiable 
project— the owner was encouraged to pursue alternative means of preserving the 
elevator by enclosing the cab itself with fire-rated glass or by constructing a fire-rated 
enclosure for the elevator shaft. 



Prepared by: Kay D. Weeks, TPS 



These bulletins are issued to explain preservation project decisions made by the U. S. 
Department of the Interior. The resulting determinations, based on the Secretary of the 
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique 
facts and circumstances of each particular case. 



84-059 




1. Rehabilitation project work on an early 20th century building focused upon meeting 
health and safety code requirements for the new use. 



84-059 




«' 



2. This shows a detail of the open dome, 
manually-operated elevator with its highly 
decorative iron grill work. Because an 
enclosed cab was required by State law, the 
historic elevator was found to be in violatioi 
of ANSI building code standards. The 
consulting engineer thus recommended its 
removal and replacement with a modern 
elevator. 



• 




3. The replacement cab featured an enclose 
cab and hollow metal shaft doors, in 
accordance with health and safety codes. 
Removal of the 1916 elevator eventually led 
to project denial because the historic 
elevator was deemed a significant interior 
feature and, thus, its retention and 
preservation were necessary to meet 
minimum preservation requirements. 



I 



84-059 





k and 5. The decoratively detailed elevator doors in the lobby (left) were to be removed 
as part of the code-required elevator replacement as well as the simpler, panelled doors 
on floors 3-7 on the west side (right). 



lical Preservation Services 
ivation Assistance Division 
rial Park Service 
Department of the Interior 
ington, D.C. 



Interpreting 



the~Secretary ot the Interior's 



"Standards tor Rehabilitation 



Number: 84-060 



Applicable Standards: 2. Retention of Distinguishing 

Architectural Character 
(nonconformance) 

9. Compatible Design for New Additions 
(nonconformance) 



Subject: ROOFTOP ADDITIONS TO SMALL SCALE BUILDINGS 

Issue: Rooftop additions are sometimes seen as a way of increasing the usable floor 
area of historic buildings located in urban areas. When this type of new addition is 
being considered, it must be designed in such a way that it is as inconspicuous as 
possible when viewed from the street. Keeping a new rooftop addition inconspicuous 
may be difficult on a small building of only two or three stories. Even if the new 
addition is set back from the plane of the facade and screened with an existing roof 
parapet, it is difficult to minimize the visual impact of an entire new floor on a 
relatively low building. On buildings with a relatively small existing floor plan, the 
recommended setback may not permit the creation of sufficient new space. This need 
to gain valuable floor space has often led to the practice of bringing the rooftop 
addition out flush with the historic facade. 

The National Park Service recognizes that some alterations and additions may be 
necessary to adapt the historic building to an efficient contemporary use. If a new 
rooftop addition to a small scale building, however, radically changes the historic 
appearance of the building so that the historic character is lost, the project will 
violate Standards 2 and 9. 

Application: A deteriorated three-story commercial building in a National Register 
Historic District noted for late 19th century commercial buildings was rehabilitated 
into mixed retail/residential use. Prominently located on a corner site flanked by 
two-story structures, the building was built in 1884 as a two-story brick commercial 
structure. In the 1890s a one-story addition was placed on the roof of the building 
flush with the exterior walls, the exterior was stuccoed and a bracketed cornice was 
added. Numerous other buildings within the historic district received similar 
additional floors as the commercial district prospered during the first three decades of 
the 20th century. These additions were flush with the facades and ornamented with 
brackets and other Victorian motifs popular in the district. 

The building was severely deteriorated, had lost its ornamental projecting cornice in 
the mid-twentieth century, and had suffered serious fire damage on the third floor 
prior to the rehabilitation (see illus. 1). The overall rehabilitation project included a 
one and a half story addition to add eight loft bedroom apartment units over the retail 
and office space (see illus. 2). 



84-060 

As the building was relatively small ( 45'x65') and as a previous addition had been flush 
with the exterior, the new addition was designed to continue the vertical expansion of 
the building flush with the existing facades in order to maximize new floor space (see 
illus. 2). To further blend the addition into the historic district, the owner determined 
that a cornice using brackets similar to the lost cornice should be installed on the new 
parapet. The spacing of the brackets, however, was modified to accommodate small 
modern windows. Dates were added to the facade to differentiate the two major 
periods of construction, 1890 and 1980 (see illus. 3). 

The owner submitted his request for certification after the rehabilitation was 
complete. The state recommended certification of the rehabilitation because it was 
consistent with the historic character of the district. The regional office denied 
certification because the addition was not consistent with the historic character of 
the building itself. Prior to the addition, the building had a simple horizontal 
character. After the height of the building had been increased by almost one-third, 
the new vertical emphasis gave the building an appearance that it never had 
historically. Furthermore, the historicizing of the details of the addition, including 
the jack-arch windows, corbelled beltcourse, pilasters, brackets and wrought iron 
cresting, eliminated any visual distinction between the new addition and the historic 
building. The use of datestones as a device was not sufficient distinction to clarify 
the periods of construction nor to preserve the historic character of the building. 

The owner appealed the decision, stating that the addition was contemporary in design 
and that it "did not destroy significant historical, architectural or cultural materials 
and is compatible with the size, scale, color, material, and character of the property, 
neighborhood, and environment." The Chief Appeals Officer sustained the denial of 
certification, supporting the regional office's determination that the size and location 
of the addition were responsible for "altering significantly its (the building's) overall 
mass, scale, and proportional relationships." While the imitative nature of the design 
of the addition had confused the historic character of the building by giving the 
building an appearance it never had, even if the design had been purely modern in 
execution, the project could not have been certified as meeting the "Standards." He 
concluded that while the building still contributed in a general way to the overall 
historic character of the District, that the rehabilitation of the building was not 
consistent with the historic character of the individual resource as a result of the 
rooftop addition and therefore, could not be certified. 



Prepared by; Sharon C. Park, AIA, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of Interior. The resulting determinations, based on the Secretary of the 
Interior Standards for Rehabilitation, are not necessarily applicable beyond the unique 
facts and circumstances of each particular case. 



84-060 




1. The building prior to rehabilitation was a three-story structure prominently located 
on a corner site in a National Register district noted for late 19th century commercial 
structures. Originally built in 1884 as a two-story brick building, a third floor was 
added in 1890, the building was stuccoed and an elaborate projecting cornice was 
applied. The cornice was lost in the mid-twentieth century and the building suffered a 
serious fire on the third floor prior to the rehabilitation. 



84-060 



2. The historic building received a one 
and a half story addition to accommodate 
eight loft bedroom apartments over the 
retail and office space. Note the change 
in scale and the dramatic vertical emphasis 
as a result of the new rooftop addition. 
As the overall mass, scale and proportional 
relationships of the building were signif i 
cantly altered, the project was denied 
certification. 





3. The new rooftop addition is not differentiated from the historic resource except by 
the use of applied dates. The addition is flush with the exterior walls and has adopted 
historicized features including wrought iron cresting, bracketed cornice, jack-arch 
windows, pilasters and beltcourses. In this case, however, the addition so altered the 
scale and massing of the building, that even if the addition had been contemporary in 
design, it could not have been certified. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting" 



the Secretary ot the Interior's 



"Standards tor Rehabilitation 



Number: 84-061 



Applicable Standards: 2. Retention of Distinguishing Architectural 

Character (nonconformance) 

3. Recognition of Historic Period 
(nonconf or m ance) 

k. Retention of Significant Later 

Alterations /Additions (nonconformance) 

6. Repair/Replacement of Deteriorated or 
Missing Architectural Features Based on 
Historical Evidence (nonconformance) 



Subject: ALTERATIONS TO NON-ORIGINAL 20TH CENTURY STOREFRONTS 

Issue : Storefronts on many 19th and early 20th century buildings were changed in the 
1920s and 1930s, incorporating new materials and designs popular at that time and 
introducing trademarks of the increasing number of commercial chains. Some of these 
later storefronts today have no intrinsic value while others merit preservation as part 
of the historic structure. 

As guidance in evaluating non-original storefronts, those that meet one or more of the 
following categories usually are worthy of retention: 

1. Exhibit high quality workmanship; 

2. Show evidence of being architect-designed; 

3. Incorporate materials not commonly used today but are characteristic of a 
particular period (e.g., curved glass, Carrara glass, bronze frames); 

k. Are representative of a particular architectural style; 

5. Are compatible with the rest of the building in terms of design and scale and date 
to a historically significant period of the building and/or district. 

Application : A two-story commercial building located in a historic district in the 
Southwest was operated until recently as part of the S. H. Kress Company store chain 
(see illus. 1). While the building dates to the early teens, the storefront had been 
altered in the late 1930s, incorporating a distinctive design which was a trademark of 
many Kress Company buildings. The band of transom windows recessed entries, metal 
framing and large glass display windows sections created the visual image 
characteristic of, and historically associated with, the Kress Company chain and its 
buildings constructed or renovated in the 1920s and 1930s (see illus. 2 and 3). Thus, 
while the 50-year age criteria of the National Register was minimally met, greater 
significance was attached to the storefront because it was part of the nationwide 
Kress Company effort in storefront design. While the new owners of the building 
originally had intended to maintain the existing storefront, breakage of one of the 



84-061 

large curved glass sections posed an unforseen rehabilitation problem since such glass 
was not readily available locally in the required safety glass. With the overall 
rehabilitation progressing quickly, the decision was made to replace the entire 
storefront with a composite design referencing features from other buildings in the 
historic district (see illus. 4). Regretfully, little physical or pictorial evidence of the 
original appearance of the building had survived. The completed rehabilitation was 
denied certification and the decision sustained on appeal primarily because of the loss 
of the intact 1930s storefront (Standard 4), but also because the new storefront was a 
conjectural historic design and contained inappropriate detailing (Standards 2,3, and 6). 
Regarding the problem of availability of materials— curved glass sections-cost was not 
the major factor but rather time. Given time, companies could have been located 
which make such custom shapes in safety glass. Unfortunately, expediency and 
perhaps only mild appreciation of the historic importance of the 1930s storefront did 
not facilitate the careful investigation of such alternatives. 



Prepared by: Charles E. Fisher, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 






■I 




f mmm warn 








1. Prior to rehabilitation, the 1930s Kress 
Company storefront had survived in place with 
nice curved entrances although the transoms 
had been covered over. 



2. Very little change to the 1930s storef 
had occurred prior to rehabilitation as ev 
by this historic photograph. 




84-061 



3. The entire storefront was replaced following breakage, during rehabilitation 
of one of the curved sheets of glass. Expediency and difficulty in locating a 
manufacturers of curved glass were cited by the owner as reasons for the change. 







P» 




■I M II ni* 



4. View of storefront after rehabilitation showing conjectural appearance 

of the original storefront — note inappropriate detailing of the transoms and small 

size of the doors. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



trie~Secretary of the Interior's 



Standards tor Rehabilitation 



Number: 84-062 



Applicable Standards: 2. Retention of Distinguishing Architectural 

Character (conformance) 
k. Retention of Significant Later 

Alterations/ Additions (conformance) 
5. Sensitive Treatment of Distinctive Features 

and Craftsmanship (conformance) 



Subject: REPLACING ALTERED FEATURES OF A HISTORIC STOREFRONT: 
COMPATIBLE CONTEMPORARY DESIGN 

Issue : Standards 2, 4, and 5 call for the retention of distinctive architectural 
features— whether original or changes that reflect the history and development of the 
building or the craftsmanship of its builders— and Standard 6 states that such 
distinctive features should be repaired rather than replaced, wherever possible. 
However, there may be cases where, over time, there has been a cumulative loss of 
historic material comprising these features and introduction of new material that 
neither exhibits a distinctive style nor special craftsmanship. (Examples of material 
loss may include decorative portions of a building such as a storefront cornice; more 
functional portions, such as its display windows, entrance doors, metal kick plates, or 
transoms; larger portions that combine structural and design roles within the overall 
storefront such as masonry, wood, or cast-iron pilasters between bays; or even the 
individual storefront bays themselves.) 

If individual features of a storefront have been altered and the alterations are not 
"changes that have acquired significance in their own right," then the preservation and 
repair requirements of Standard 6 do not apply. In these cases, the nonsignificant 
later features may be removed and compatible replacement features designed and 
installed as long as the new work preserves any remaining historic material, the 
storefront character is preserved, and the overall rehabilitation is consistent with the 
historic character of the building. The option of replacing features, such as storefront 
doors or windows would, however, never extend to later, distinctive features that help 
define the storefront character. 

In summary, it is cautioned that a thorough professional evaluation be made prior to 
removal to ascertain both the significance of individual storefront features as well as 
their potential for repair. Demolition of distinctive architectural features and 
craftsmanship can be the basis for denying an entire rehabilitation project. 

Application A 6-story brownstone and terra-cotta structure built in the 1890s and 
located in a historic district in a southeastern city was being rehabilitated for retail 
and office use. Proposed exterior work included removal of nonoriginal 20th century 
storefront infill features— transoms, double doors, glass display windows, and concrete 
block kick panels (see illus. 1, 2). A contemporary replacement storefront would then 
be installed within the original cast-iron columns, pilasters, and framing, thus 
retaining the three-bay division of the historic storefront. The owner's primary reason 



84-062 

for removing much of the later storefront— those nonoriginal portions—was to 
integrate an additional code-required fire exit into an overall design scheme that he 
felt would successfully reflect the building's new use as an art gallery. 

In its initial review, the SHPO recommended approval of the project work, but 
expressed concern over whether or not the 20th storefront infill features had acquired 
significance over time. In the regional review, the project was denied certification. 
In a letter to the owner, the reasons for denial were explained: 

We have reviewed your proposal to replace the existing storefront 
with a new entrance of contemporary design that would meet the 
code requirement of providing a second fire exit. Though not original 
to the building, the storefront appears to be of sufficient age and 
design quality to have gained significance in its own right; we feel 
that its removal would violate Standards 4 and 5. Although we 
recognize the need to install a fire exit through one of the side 
display windows, alternative methods were suggested to the architect 
by this office that would avoid damaging the significant portions of 
the storefront (i.e., the gridded transom windows and double doors) 
and which would not require replacement of the entire storefront. ..In 
the absence of documentation demonstrating that the existing 
storefront is not significant in terms of its age, period, style, 
materials, or condition, we cannot approve its removal for the 
purpose of installing a modern entrance to the building. 

Because the owner felt that the existing storefront needed to be altered to accommodate 
code; that the altered portions were not important historically; and that the 
contemporary storefront met Standard 9, the region's decision was appealed. Prior to 
appeal, the SHPO offered a final recommendation on the storefront replacement issue in 
a letter to the Chief Appeals Officer, supporting the owner's contention that new 
evidence seemed to indicate that most of the later alterations to the storefront had post- 
dated the 1930s: 

In our initial review of the project, much discussion occurred 
concerning the significance of the existing storefront. While the 
existing storefront, which is obviously not original, is of nice design, 
it is not of sufficient quality to say that the storefront has acquired 
special significance in its own right or that it is important to retain 
the storefront to show the evolution of the building through history. 
In addition, I have personally inspected the building and believe that 
the storefront is not representative of any particular stylistic period 
and is not an example of skilled craftsmanship or a good example of 
design and use of material. 

On appeal, the regional decision was overturned and the project subsequently certified 
for preservation tax benefits. In a final letter to the owner, the Chief Appeals Officer 
stated: 

After carefully considering information submitted by your architect 
concerning the construction detail and dating of the existing 
storefront and comments provided by the State Historic Preservation 
Officer, I have determined that the proposed project meets the 



Secretary's Standards. I share, however, some of the concerns of the 
regional office regarding proposed storefront design. While I have 
concluded that the existing storefront has not acquired special 
significance over time nor exhibits significant stylistic features or 
craftsmanship, 1 would encourage you to consider a contemporary 
design that provides greater visual distinction between the transom 
and the display windows. I would also encourage you to revise your 
design to provide for solid base panels beneath the windows and 
doors. These alterations would, I feel, be more in keeping with the 
historic character of the building and district yet would clearly 
"read" as new construction. 

After removal of the altered, nonhistone portions of the storefront, the compatible new 
infill was installed, thus retaining and preserving those original portions identified as 
historically significant (see illus. 3,4). 

Prepared by: Kay D. Weeks and Charles E. Fisher, TPS 

These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of the 
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique 
facts and circumstances of each particular case. 



84-062 




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jchnical Preservation Services 
-eservation Assistance Division 
ational Park Service 
.S. Department of the Interior 
Washington, D.C. 



Interpreting 



the~Secretary of the Interior's 



Standards tor Rehabilitation 



Number: 84-063 



Applicable Standard: 7. Cleaning with Gentlest Method Possible 

(nonconformance) 



Subject: INAPPROPRIATE CHEMICAL CLEANING OF HISTORIC MASONRY 
BUILDINGS 

Standard 7 of the Secretary of the Interior's Standards for Rehabilitation states that 
"the surface cleaning of structures shall be undertaken with the gentlest means 
possible. Sandblasting and other cleaning methods that will damage the historic 
building materials shall not be undertaken." While "the gentlest means possible" is 
usually interpreted to mean chemical cleaning, water, or water with the addition of 
detergents, it is important to realize that these methods too, can be damaging to 
historic building fabric. Cleaning techniques involving water or chemicals are not 
infallible, and must always be tested. If carried out improperly — for instance, if the 
chemical mixture is too strong, if chemicals are not adequately rinsed out of the 
masonry, if wet cleaning methods are undertaken during cold weather or if there is 
still a possibility of freezing temperatures — such cleaning methods can physically 
abrade or otherwise visually damage historic masonry. In short, chemical cleaning 
may not be "the gentlest means possible." Historic masonry buildings ( and brick 
buildings in particular) which have been chemically cleaned in a way that has resulted 
in damage to the visual or aesthetic qualities of the masonry, may be denied 
certification for tax benefits. 

Application No. 1: A 1912 bank and office building constructed of brick with stone 
and terra cotta trim was rehabilitated for contemporary office use after being vacant 
for several years (see illus. 1). Located at a major downtown intersection, this nine 
story building is a prominent and highly visible landmark throughout the city, towering 
as it does above the more modestly scaled two to three story neighboring buildings. 
The proposed project which was given preliminary approval by the National Park 
Service, and was carried out in 1982, included refurbishing of office suites on the 
interior, chemical cleaning of the exterior masonry, and replacement of the later 
1940's storefront infill with more appropriately scaled window glass. 

When the completed project was submitted to the National Park Service for final 
review, however, it was denied certification on the basis of the cleaning techniques 
which had resulted in "severe discoloration and splotching of the brick surfaces" (see 
illus. 2). The region's denial letter went on to say: "The brick was apparently cleaned 
with an inappropriate chemical cleaner which was not adequately tested before its 
use, contrary to the recommendations contained in the Secretary's Guidelines for 
Rehabilitating Historic Buildings. Although the physical damage to the brick was not 
documented, the region felt that the visual change to the brick surface was sufficient 
to deny the project, citing violation of Standards 7 and 2. 



84-063 

When the owner appealed the denial he explained that the exterior of the building had 
actually been cleaned and treated with a water repellent two times . Unsatisfied with 
the result after the first chemical cleaning, the owner required the cleaning 
contractor to reclean the building in what turned out to be a futile attempt to improve 
the appearance of the brick. During the appeal, the owner was unable to identify the 
type of chemicals or the methods used in the cleaning, nor did he provide any close-up 
photographs of the discolored brick. Consequently, it remained unknown whether the 
chemical cleaning had also caused physical damage to the brick. 

After careful review of the project, the Chief Appeals Officer sustained the region's 
decision, stating that: "I concur with the regional office's finding that this treatment 
(cleaning of the exterior brickwork) 'has so altered the appearance of the building as 
to detract from its historic character.' Standard 7 permits only the gentlest means of 
surface cleaning... Close-up photographs showing the conditions of the brick before 
and after this process (the second cleaning) were not submitted, nor were technical 
details of the cleaning methods and substances made available. Nevertheless, it is 
convincingly evident from the extent and degree of the persistent discoloration that 
the brickwork was subjected to unacceptably harsh cleaning. Accordingly, I find a 
violation of Standard 7." 

Application No. 2: In a second case, a mid-nineteenth century brick rowhouse was 
rehabilitated for rental residential use (see illus. 3). A major aspect of the 
rehabilitation of the exterior was the removal of paint covering the brick facade. The 
project application stated that the building was to be chemically cleaned, generally an 
acceptable paint removal technique in accordance with the Secretary of the Interior's 
"Standards for Rehabilitation," and the proposal was given preliminary approval by the 
National Park Service. However, when the request for final certification was 
submitted, photographs showed that the "cleaned" brick appeared to have been 
damaged by the cleaning method (see illus. 4). When questioned, the owner revealed 
that the paint had been removed with sodium hydroxide, more commonly called 
caustic soda or lye. With the knowledge that some types of chemical cleaning may be 
just as damaging to historic brick as sandblasting, it was decided that an on-site 
inspection of the property by the National Park Service was necessary in order to 
determine if, indeed, the brick really had been damaged by this method of paint 
removal. At the project site, comparison of the cleaned brick with the painted brick 
of an identical row house on the same block provided evidence (see illus. 4 and 5) that 
the surface of the rather soft brick had been "etched" by lye. 

On that basis, the project was denied certification by the National Park Service 
Regional office. The denial letter sent to the owner stated: "The National Park 
Service has been cautioning property owners for some time about the dangers of paint 
removal and cleaning of soft masonry. The (State Historic Preservation Office) has 
been advising property owners concerning the early practice of painting 
many...rowhouses for aesthetic reasons and as a protective treatment for inherently 
poor quality brick. We strongly urge you to be more cautious in future projects when 
you consider removing paint from historic masonry; we would encourage you not to 
remove paint where historically such surface treatment has acquired significance over 
time. Where paint removal is an appropriate treatment, only the gentlest means 
possible, determined by careful testing, should be used. If no method can be found 
which does not damage the brick or change its original visual appearance, the paint 
should not be removed." 



84-063 

When the owner appealed this decision, the Chief Appeals Officer upheld the denial of 
the regional office, explaining that "as a result of the cleaning, the surface of the 
brick has been eroded, exposing additional folds and irregularities in the clay and 
creating a rougher texture to the brick. These visual and physical changes to the brick 
have altered the character of the masonry facade." 

Prepared by; Anne E. Grimmer, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



84-063 





<3 III 
%1 III 




1. Nine story bank and office building 
before rehabilitation. Note uniformity 
of brick color. 



2. Office building after chemical 
cleaning showing splotchy and discolored 
brick. 



84-063 




3. Brick rowhouse in center after paint 
removal using sodium hydroxide stands 
out conspicuously from its still painted 
neighbors. 



84-063 




■*y*\s 



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— >% 



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/ y 







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■ 


u 


k 




J 




1 ■ ma, 



k. Close-up view of uncleaned partially 
painted wall with original paint. Note 
relatively smooth surface of this brick on 
identical house on same block 




5. Close-up view of chemically cleaned 
brick showing deep ridges and newly 
abraded texture. 



;hnical Preservation Services 
servation Assistance Division 
tional Park Service 
>. Department of the Interior 
shington, D.C. 



Interpreting 



the Secretary ot the Interior's 



Standards tor Rehabilitation 



Number: 84-064 

Standards for Evaluating Significance Within 
Registered Historic Districts (36 CFR 67.5 
(a)(2)) 

Subject : EXTENSIVE REPLACEMENT OF HISTORIC MATERIALS/FEATURES: 
LOSS OF INTEGRITY 

Issue: In' planning any rehabilitation project, it is assumed that some historic materials 
(masonry, wood, and metal) will be deteriorated or damaged and need repair or 
replacement in preparation for the new use. While a reasonable level of replacement of 
such deteriorated or damaged exterior and interior material is acceptable, at the same 
time the preservation requirements outlined in 36 CFR 67 must always be met. To 
receive Part 1 certification, the building, prior to rehabilitation, must convey historic 
significance through its intact features, i.e., display integrity of design, materials, and 
workmanship, location, feeling, and association according to the Secretary of the 
Interior's "Standards for Evaluating Historic Significance Within Registered Historic 
Districts;" and to receive Part 2 certification, the building, after rehabilitation, must 
retain those portions and features of the building that have been identified as significant 
prior to work, in accordance with the Secretary of the Interior's "Standards for 
Rehabilitation." 

If, after close inspection, it becomes clear that the significant portions and features of 
the building cannot be retained and preserved because of the extent of physical 
deterioration or damage, then the building will generally not possess sufficient integrity 
of design, materials, and workmanship to be designated as a "certified historic structure" 
and, in consequence, Part 1 certification should be denied. In unusual cases where Part 1 
certification has already been issued and, during the course of rehabilitation, it is 
discovered that the structure does not possess sufficient integrity, the Part 1 
certification should be rescinded and the Part 2 application returned to the owner, 
unprocessed, with a letter explaining the action. 

Application: A deteriorated, three-story, three-bay wide brick structure built in 1843 
was certified in the Part 1 application as contributing to the significance of the 
registered historic district— a 13 block area of 19th century Federal and Greek Revival 
structures (see illus. 1,2,3,4). 

A Part 2 application was submitted at the same time as the Part 1 application, but a 
determination on Part 2 could not be given due to a lack of information concerning the 
below-grade storefront which the owner proposed removing as part of the work to return 
the building to a residential appearance. The letter from NPS, WASO requesting 
additional information, stated: 

Although the application material indicates that the structure 
was originally residential, the photographs suggest that the 
storefront, including the projecting bay with side entrance 
door and cornice, may have acquired historic significance over 
time. For this office to make a Part 2 assessment, however, 



84-064 

you will have to provide information concerning the building's 
conversion on the lower floor to commerical use and the 
approximate date of the existing storefront. Photographs of the 
storefront showing in more detail what had survived should be 
submitted. When additional information and photographic 
documentation is received, a determination can be made as to 
whether the project meets the Standards for Rehabilitation. 

In response, the owner submitted the requested information on the storefront in order 
to process the Part 2 application; this particular work component was reviewed and 
found to be in conformance with the Standards. 

The amended application also included new photographic documentation that revealed 
the severely deteriorated condition of previously blocked-up portions of the rear of 
the building and the extent of damage and loss of both exterior and interior features. 
This portion of the building had not been assessed in the initial application, but was 
assumed to be substantially intact when Part 1 certification was issued. The newly 
submitted photographic documentation called into question the integrity of design, 
materials, and workmanship of the building, and it was decided to re-evaluate the 
Part 1 certification (see illus. 5,6,7). Following re-assessment, a second letter was 
sent to the owner, explaining the region's findings: 

Based on the information submitted in the original application, 
the National Park Service determined that the property 
contributed to the significance of the registered historic 
district in which it was located, and thus qualified (for tax 
benefits) as a "certified historic structure." This certification 
was based on the assumption that a majority of the structure 
was still standing and that character-giving features such as 
interior trim, moldings, and fireplace details would be 
retained... 

The new photographic documentation that you submitted shows 
that barely one-third of the building was standing at the time 
rehabilitation work commenced. As a result of the building's 
extremely deteriorated condition, significant architectural 
features are too deteriorated to be preserved on the remaining 
portion of the building. In addition, nearly all interior finishes 
are to be replaced and rebuilt using new materials. As a result 
of the new information, we have determined that No. 2 of the 
"Standards for Evaluating Significance Within Registered 
Historic Districts" has been met (e.g., the structure does not 
contribute to the significance of the district) and, therefore, 
the building cannot qualify as a "certf ied historic structure." 
This decision supersedes the earlier decision.. .Since the 
building does not qualify as a "certified historic structure," in 
accordance with Department of Interior regulations, the 
project is not eligible for certification of rehabilitation. 

Because the owner felt preservation tax incentives should be made available and the 
Part 2 processed, the project was appealed. On appeal, the region's denial of Part 1 
was affirmed by the Chief Appeals Officer, who reiterated: "Similarly, I have 



84-064 

determined that it is not a certified historic structure because the integrity of the 
original design, individual architectural features and spaces have been irretrievably 
lost through physical deterioration and structural damage..." 



Prepared by: Kay O. Weeks, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



84-064 





1. Although photographic documentation submitted 
with the Part 1 application showed some deterioration 
and loss on the primary elevation, NPS determined 
that the building exhibited sufficient "integrity" to 
qualify as a certified historic structure. 



2. Limited demolition at the rear of 
the building had already occurred and 
protective boards had been applied. 





3, 4. The interior, with intact trim and mantels helped define 
the character of this simple, mid- 19th century structure. 



84-064 





5. Crucial to the decertification of the structure 
were additional photographs documenting the condition 
of the rear of the building prior to rehabilitation. 
After removal of the boards, this new information 
showed that barely 1/3 of the building remained. 



6. The plan indicates the extent 
of material loss that had occurred 
prior to rehabilitation, including 
exterior and interior features. 



SO 2 



7 



7. The rear of the building and major portions of 
the interior required extensive replacement of 
historic material with new material. 





\UU E 


5; 


II I 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, DC. 



Interpreting. 



the Secretary of the Interior's 



Standards tor Rehabilitation 



Number: 85-065 

Applicable Standards: 1. Compatible New Use (conformance) 

2. Retention of Distinguishing Architectural 
Character (nonconformance, conformance) 

5. Sensitive Treatment of Distinctive Features 

and Craftsmanship (nonconformance, conformance) 

6. Repair/Replacement of Deteriorated or 
Missing Features (conformance) 

9. Compatible Design for New Alterations/Additions 
(nonconformance, conformance) 

Subject: Alterations to Historic Auditorium Spaces 

Issue: Changing the use of historic auditorium spaces, such as those in theatres, churches 
and schools, poses difficult design problems. Some new uses cannot be accommodated in 
such auditoriums without destroying character-defining spaces or features. Dividing the 
space, or altering or destroying its features will result in a denial of certification for 
noncompliance with Standards 2 and 5. However, there are cases where earlier 
insensitive alteration to, or extensive deterioration of, the materials comprising 
significant features and spaces has already resulted in loss of the historic character. In 
such cases, further alterations to accommodate a new use will generally not result in 
denial of rehabilitation certification. It is particularly important, however, that a 
careful professional evaluation be made of altered spaces and deteriorated features to 
assure that repair is, indeed, infeasible. 

Applications: A small church built in 1875 in the Gothic style and located in a historic 
district had been purchased by a neighboring church in 1923 for use as an educational 
facility. During the 1960's it had been used as a theater and recreational center (see 
illus. 1 and 2). A proposal was made to rehabilitate the structure into residential 
condominiums (see illus. 3). In order to accomplish this conversion, the owner proposed 
to subdivide the interior space and to insert three new floor levels into the sanctuary. 

The regional office denied the project preliminary certification on the basis that the 
"austere interior is of major importance" in defining the "ecclesiastical character of the 
structure." It found that inserting seven residential units into the interior would 
seriously impair that character. While the concept of inserting residences into the 
church was not ruled out, the plans as submitted were deemed unsatisfactory because 
they involved the "total loss of the original volume and space of the sanctuary." 

Upon appeal the owner stressed the alterations made to the interior during the previous 
20 years. The "austere" appearance resulted, he stated, from the gutting of the interior 
to provide a basketball court. The interior did not, therefore, contribute to the overall 
character of the building. He further stated that "the sense of volume and the 
ecclesiastical character of the former church will be retained in the individual apartment 
units. After the rehabilitation, this building will look like a church, as it does now." 



85-065 

In his decision upholding the denial of certification, the Chief Appeals Officer 
determined that changes made to the interior over the years had not seriously diminished 
the historic character of that space. The alterations, he said, "appear to amount to little 
more than removal of church furnishings." He noted that the church retains such 
features as the regularly spaced windows, the conspicuous roof structure and exposed 
scissor trusses, and that the extent and form of the space remain. Overall, he concluded, 
the interior still conveys a sense of the purpose for which it was designed—assembly. 
The interior space, therefore, was determined to be integral to the historic character of 
the building. Because that space would be destroyed by the insertion of apartments as 
planned, certification was denied. 

A second case involved an 1890's brownstone, Romanesque Revival church with an 
octagon plan sanctuary, individually listed in the National Register, and located in a 
residential section of a major northeastern city. A rehabilitation was proposed to 
convert the building, which had been empty for fourteen years, to medical offices. The 
new use necessitated insertion of three floors and office partitions into the sanctuary 
(see illus. 4). The interior had ornate, clustered, engaged colonettes; acanthus leaf 
entablatures; a wooden chair rail; four arched tripartite windows; an egg-and-dart ceiling 
cornice; and a shallow dished ceiling. Plans called for enclosing most of the deteriorated 
plaster detailing on the walls with furred-out walls, and removal of the lath and plaster 
of the dished ceiling (see illus. 5). 

The church had been converted to a synagogue in 1948, at which time the organ; organ 
chamber; choir, choir gate, and railing; pulpit; stained glass windows; and pendant 
lighting fixtures had been removed. Shortly afterward (early 1950's), an acoustical tile 
ceiling and recessed lighting were installed. During fourteen years of disuse, the 
building's attic and tower had become infested with pigeons, little maintenance had been 
done, the building was without heat, and had been vandalized. 

The NPS regional office denied the proposal preliminary certification, citing Standards 1, 
2, 5, 6, and 9. The decision was predicated on an evaluation of the sanctuary space and 
its elaborate ornamentation as essential to the historic character of the building. The 
region determined that, "although parts of the historic fabric were water-damaged and 
although alterations had occurred, the sanctuary had not lost its ability to convey 
historical associations and the damaged features were repairable." The denial letter 
stated that the installation of new floors and partitions that "leave no area for 
perception of even part of the original, grand, open plan" violates Standards 1, 2, and 9. 
The removal of the ceiling, enclosure of decorative detailing, and replacement of (1948) 
windows violates Standards 2, 5, and 6. 

In appealing the regional denial, the owners stated that the dished ceiling plaster and lath 
(as well as the applied acoustical tile) would have to be removed, as they were soaked 
with water from the numerous roof leaks, and had a thick layer (as much as one foot) of 
pigeon excrement above. Further, due to water penetration and freeze-thaw cycles, the 
decorative plaster on the sanctuary walls was severely damaged and so unstable as to be 
unable to withstand even the slightest impact. 

At the appeal meeting, close-up photographs of deteriorated plaster details were shown 
(see illus. 6), and the condition of the plasterwork was fully discussed. The Appeals 
Officer overturned the regional office denial and determined that the project was 
consistent with the existing historic character of the church. In certifying the project, 
he said: 



85-065 

The information and photographs (as well as the physical evidence) you provided 
clarified for me the condition of the building. ..I am convinced that the 
plasterwork has deteriorated to such an extent that it cannot now be repaired, 
and that the interior wall and ceiling finishes have lost their physical integrity 
and their historic character. 

Church sanctuaries are often character-defining features of historic churches. The 
importance of these spaces, however, is not dependent on the ornateness of detailing. 
The first space discussed here was plain; the second was elaborate. In neither case did 
evaluation of the proposed project depend on the level of ornamentation. Minor changes 
had been made to the first church interior, but the materials and the sanctuary space had 
remained intact. In the second case, the sanctuary had lost its character due to extreme 
deterioration. Regardless of the original level of detail, if a character-defining historic 
interior remains largely intact, it must be retained in a rehabilitation. Subdivision or 
other alteration that destroys the form or features of a significant space will result in 
denial of certification. 

Prepared by ; Michael Auer and Susan Dynes, TPS 

These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



85-065 




1 and 2. Interior of the church at the time rehabilitation planning 
commenced. Remaining features include regularly spaced windows, 
roof structure and exposed scissor trusses, original floor to ceiling 
height. Only the church furnishings had been removed. 




85-065 




3. Section showing proposed insertion of two floors and a hallway within the sanctuary. 



S5-065 



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85-065 




6. Detail of sanctuary perimeter wall with engaged colonettes and obvious plaster deterioration. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



the~Secretary of the Interior's 



"Standards tor Rehabilitation 



Number: 85-066 



Applicable Standards: 1. Compatible New Use (Conformance) 

2. Retention of Distinguishing Architectural 

Character (conformance) 
9. Compatible Design for New 

Alterations /Additions (conformance) 
10. Reversibility of New Alterations/ Additions 
(conformance) 

Subject : INTERIOR ALTERATIONS TO CHURCH STRUCTURES TO 
ACCOMMODATE NEW FUNCTIONS 

Issue: Rehabilitation of any historic building should always take into consideration the 
preservation of significant interior spaces, materials and features. This is particularly 
important when evaluating churches because the large, open spaces frequently are 
significant character -defining features. Preservation of the exterior form and shape 
of a church structure is of obvious importance, but because the exterior is essentially 
a reflection of this interior space, successful rehabilitation of a church structure 
ultimately depends on finding a new use that respects this character-defining 
feature. Generously scaled open space is characteristic of even a simple country 
church and like other types of auditorium spaces, such an interior does not readily lend 
itself to very many other uses. Selection of a new use that respects the character of 
this space and any distinctive architectural details is a critical first step in meeting 
the Secretary of the Interior's "Standards for Rehabilitation." Once a new use is 
found, its functional requirements must be adapted to fit into the existing space 
without damaging or adversely affecting its historic character. 

Application : A small turn-of-the-century board and batten Gothic Revival church 
located on a rural wooded site had stood vacant and unused for nearly thirty years (see 
illus. 1-2). Built on the brick foundation of an earlier church constructed in the 1870's, 
the church has a nave 5 bays in length covered by a steeply pitched gable roof. The 
gabled entrance porch on the south side of the nave is distinguished by stickwork 
detailing outlining the gable. Lancet windows light the nave, and the 2-bay long apse 
features a tripartite stained glass window opposite a pair of stained glass windows 
with a stained glass roundel above on the west end of the church. The vestry room, a 
small gabled section (matching the entrance porch) projects off the north side of the 
apse. A square bell tower with a shingled spire dominates the north side of the nave 
opposite the entrance porch. The simple interior is highlighted by exposed oak roof 
beams, arched trusses, and matchboard ceiling and wainscotting (see ills. 3-4). 
Individually listed on the National Register, this building had essentially retained most 
of its original fabric, as well as its form and pristine country setting, all of which 
contributed to its historic character. The church did not have plumbing, electricity or 
a modern heating system when the owner purchased it with the intention of converting 
it into an artist's studio and residence. 



85-066 

The rehabilitation (already underway when the Part 2 Historic Preservation 
Certification Application was submitted to the National Park Service), included the 
installation of mechanical systems, insertion in the nave of 2 small pent -roof ed sheds 
to house a bathroom and storage, construction of a spiral staircase and a mezzanine 
above the chancel to function as a sleeping loft, conversion of the vestry room into a 
kitchen, and the cutting of three skylights into the north side of the roof of the nave. 

When the project was reviewed by the National Park Service, the determination was 
made that the cumulative effect of the rehabilitation work violated Standards 2, 9, 
and 10, of the Secretary of the Interior's "Standards." Cited in the denial letter was 
the installation of the large skylights into a "major roof slope," dramatically altering 
the exterior appearance of the building and on the interior flooding the dark ceiling 
with light, not only changing a distinctive and character -defining feature (in violation 
of Standard 2), but also resulting in loss of historic roof fabric (in violation of Standard 
10). The addition of a mezzanine in the chancel and a circular stair in the center of 
the arch at the chancel entrance were cited as being incompatible with the character 
of the building (in violation of Standards 2 and 9), as was the insertion of the bathroom 
and storage sheds in the nave because their construction changed the nave space and 
its visual relationship with the chancel. 

The owner appealed the denial, arguing that the skylights were not highly visible on 
the exterior to passers-by, as that elevation of the church faces onto an abandoned 
cemetery, not a public-right-of-way. Furthermore, their installation did not result in 
extensive loss of historic fabric because materials removed were used to patch 
damaged areas of the roof. The owner also stated that the mezzanine and stairway 
inserted in the chancel and the bathroom and storage sheds in the nave were 
sensitively designed and compatible with the historic character of the church (see 
illus. 5-6). 

After careful review of the project and newly submitted photographic documentation 
of the now completed work, the Chief Appeals Officer reversed the denial, and 
certified the rehabilitation. The Chief Appeals Officer, exDlaining his decision in a 
letter to the owner, agreed with the owner that the alterations to the interior were 
not inconsistent with the historic character of the historic resource. 

The skylights were introduced directly behind the bell tower in the north 
slope of the roof which faces away from the principal approach to the 
building; they are not obtrusive from the exterior, nor are they so numerous 
as to adversely affect the character of the interior. The mezzanine, 
circular stair and sheds were introduced to the interior with minimal 
damage to the historic fabric. While the chancel arch was partially 
enclosed in inserting the mezzanine, the windows in the east wall remain 
visible through the glass panels and open circular stair. The pendant sheds 
constructed in the nave similarly respect the axial lines and tunnel-like view 
of the church interior from the west end towards the east. In fact the slope 
of the shed roofs focuses the lines of sight toward the chancel and the 
windows beyond (see illus. 6). The changes made to the interior of this 
building are consistent with the historic character of this historic structure, 
and I find them in conformance with the Secretary of the Interior's 
"Standards for Rehabilitation." 



85-066 

Finally, the Chief Appeals Officer concluded that his decision to overturn the denial 

was also, 

...based in large part on the sensitivity to the setting of this 
structure. ..evident in the decisions you made regarding the use and 
treatment of this building. The property surrounding it retains its rural 
character and this setting contributes greatly to its historic character as a 
country church. Your rehabilitation preserves the setting and aDpearance of 
the church exterior, (see illus. 7) 

Prepared by ; Anne Grimmer, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



85-066 




1. South elevation of church before rehabilitation. 




2. North elevation of church before rehabilitation. 




85-066 



3. View of nave looking west toward baptistry 
before rehabilitation. 




View of nave looking east into 
apse and sanctuary before 
rehabilitation. 



85-066 




5. North elevation showing new skylights inserted 
in nave roof after rehabilitation. 




6. View of nave looking east. Note the 
2 new sheds in front of and on either 

side of spiral stairs in center of 
sanctuary arch leading to mezzanine. 



85-066 




7. South elevation of church after rehabilitation. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Deoartment of the Interior 
Washington, DC 



Interpreting 



tne~Secreta r y of the Interior's 



Standards tor Rehabilitation 



Number: 85-067 



Applicable Standards: 6. Repair/Replacement of Deteriorated or 

Missing Architectural Features Based on 
Historical Evidence (conformance) 
9. Compatible Contemporary Design for New 
Alterations/ Additions (conformance) 



Subject: OPTIONS FOR REPLACING MISSING HISTORIC FEATURES 

Issue: When a certified historic structure which otherwise possesses integrity is missing 
a significant feature of the primary elevation, a particularly important decision has to be 
made as to how to treat this portion of the building's history that has been lost. 

If physical evidence and/or pictorial documentation is available and restoration of a 
missing feature of the facade is desirable, the most traditional and often preferred 
approach is to accurately recover it in both form and detailing so that the entire facade 
appears to be "historic" Although the missing feature is actually new material, the 
historic form is re-established. 

If the restoration option is chosen, the replacement feature needs to be evaluated on its 
accuracy of form and detailing, whether the replacement feature is made of matching 
historic material (wood, masonry, or architectural metal) or a compatible substitute 
material. In this regard, it should be noted that it is not acceptable to replace a missing 
historic feature with a feature that conveys a false or confusing sense of history— that 
glamorizes the missing historic feature; or otherwise gives the building a "historic" 
appearance that never existed. 

A second acceptable, but potentially difficult, approach is to replace a missing feature 
with a compatible new feature. This option can be quite successful within a 
rehabilitation project because, as opposed to recovering the historic configuration with 
new materials, it honestly acknowledges loss of the historic feature, then gives the 
replacement feature—such as a compatible, contemporary storefront— a legitimacy of its 
own within the rehabilitation. 

If a compatible contemporary approach to replacement is chosen, a very different 
process needs to be used to evaluate the project for conformance with the Standards. 
This process should begin with an assessment of the remaining historic features of the 
facade. Any new work then has the dual goal of preserving and retaining those 
significant aspects that have survived; and of suggesting that an important element of 
the facade was missing but has now been replaced. Such a replacement feature should 
approximate the form of the missing historic feature, clearly reading as new through 
avoidance of historicized detailing. Modern materials may assist in conveying a 
contemporary appearance, but their use is not required. 



85-067 

It should be recognized that once a significant feature is lost through deterioration, 
alteration, or vandalism, even a thoroughly documented and carefully crafted 
replacement feature is no more than an interpretive facsimile. Therefore, whether or 
not physical evidence and pictorial documentation exist that could be used to restore the 
missing feature such as a porch or cornice or storefront, a third option— although not 
widely accepted in a historic preservation context— is to simply acknowledge the loss as 
part of the evolution of the historic building. 

In summary, the three options for replacing a missing feature are as follows: 

1. Use pictorial documentation and/or physical evidence to re-create the historic 
feature. 

2. Acknowledge loss of the missing feature, then re-evaluate the features of the 
existing facade to design a compatible new replacement feature that does not alter 
or damage the remaining character-defining portions that convey historic 
significance. 

3. Accept the loss; do not replace the missing historic feature. 

Applications; In the first case, a significant storefront of a "contributing" nineteenth- 
century limestone building had been extensively altered; in addition, a highly decorative 
and equally significant cornice was missing (see illus. 1). In the rehabilitation project, 
the owners elected Option 1, above, to restore both altered and missing portions of the 
building using physical evidence and pictorial documentation (see illus. 2). Overall work 
included cleaning and repair of the limestone; repair of window sash and frames; 
replacement of the missing cornice using fiberglass elements and, following removal of 
the later, altered storefront features, an accurate duplication of the historic design was 
constructed (see illus. 3). The project has received preliminary certification for the 
investment tax credit. 

In the second case, a former theatre building located in a midwest historic district was 
determined to be a contributing element, in spite of the fact that it had been extensively 
altered in the 1960s for use as offices. The original glazed wooden double doors, (see 
illus. 4), had been removed and the openings filled in with glass block as part of the 1960s 
renovation (see illus. 5). Also, in order to level the sloped theatre entrance floor, 
concrete had been poured in the front 15 feet of the building to a thickness of 22 inches 
at the facade. 

The recent rehabilitation project for which certification was requested included 
substantial interior office renovation; removal of small areas of the later paint to 
determine the original brick colors and painting over the gray paint to approximate them; 
replacement of the deteriorated second-floor casement windows with matching sash; and 
replacement of the 1960's glass block in the first floor openings with large steel-framed 
windows and transoms (see illus. 6). The owner felt that the new windows were 
compatible with the remaining character-defining features of the historic facade, as 
outlined in Option 2. 

After review, the regional office denied the project certification based on an assessment 
that the new first floor windows violated Standards 6 and 9. The denial letter stated: 

Although there is no question that the block infill.. .was not significant, the 
rehabilitation of the building should have either left the existing conditions 



85-067 

in place, been based on a significant documented period of the building, or 
reflected a predictable treatment to the age, style, use and detail of the 
building. The windows installed in place of later inappropriate glass block 
infill followed none of these approaches. 

Because the owner felt that the new design was compatible, in accordance with Standard 
9, and that the installation of doors was not possible because of the poured concrete and 
the use of the building, the denial was appealed. 

After carefully evaluating the facts, the Chief Appeals Officer reversed the regional 
decision, finding that the overall rehabilitation was consistent with the historic character 
of the former theatre building. An assessment of the building's facade, without the 
distinctive wooden double doors, revealed that the historic character of the facade now 
consisted of the prominent projecting central pavilion, together with the pattern of 
narrow vertical openings on the second floor, the freestanding piers, and the patterned 
brick. One option was to accurately restore the form and detailing of the missing 
doors. But an equally acceptable option was to acknowledge their loss and select a 
compatible contemporary solution. Since the doors were now gone, retention of the 
significant openings in the rehabilitation was a key preservation objective. Whether 
these openings were used as doors or as fixed windows was not an issue in the appeal. 
However, if the existing openings had been altered, changing the historic proportions, or 
the piers or patterned brickwork changed, the historic character would clearly have been 
diminished. This project, however, retained and preserved the remaining character- 
defining features of the facade. 

In approving the project, the Chief Appeals Officer held that the owner had met the 
requirements of Option 2, to design a replacement feature that did not alter or damage 
the existing masonry openings, or did not have a negative visual impact on the facade. In 
fact, the new work successfully borrowed elements from the documented historic doors 
in the compatible contemporary approach, as stated in a final letter reversing the 
region's denial: 

The restrained design of the new windows repeats proportions from the 
original doors, which are known from a historic photograph. The stone 
panels recall the major horizontal division established by the large kick- 
plates on the doors, the vertical mullions indicate the original division 
of each bay into two doors; and the new transom approximates the 
proportion of the original transom. Replication of the original doors, 
based on the historic photograph you have, would have been an 
acceptable preservation treatment as well... 

Prepared by; Kay D. Weeks and Susan Dynes, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of the 
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique 
facts and circumstances of each particular case. 



85-067 




1. At the outset of rehabilitation, an 1866 limestone 
building was missing its ornamental cornice; and the 
ground level storefront had been extensively 
altered. 




HfUtfij 



i 




ii nn ii I 




-*n. 







2. Based on the availability of this and other 
photographic documentation, the owners were able 
to accurately restore both the cornice and the 
storefront to their historic configuration. 



3. In addition to restoration of the 
storefront using matching materials, this 
photograph of finished work shows an 
acceptable use of substitute material (in 1 
case, fiberglass) to fabricate the missing 
pressed metal cornice. 




85-06 




k. Historic photograph of the theatre's facade as it appeared in 1913. Note the glazed wooden 
double doors, repetitive features that, together with the distinctive rectangular openings 
themselves and the patterned brickwork, define the architectural character of the building. 



» 




5. Theatre building as it appeared at the commencement of rehabilitation. The wooden doors had 
Deen removed in an earlier "renovation" and the openings f illed-in with glass block. In addition, 
the masonry was painted a uniform gray. The stone sills cover a 22-inch-thick concrete floor 
nside. 



S5-067 




Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, DC 



Interpreting 



ffie~Secretarv of the Interior's 



Standards tor Rehabilitation 



Number: 85-068 



Applicable Standard: 2. Retention of Distinguishing Character of 

Building and Environment (nonconformance) 

Subject: REMOVAL OR ALTERATION OF HISTORIC SITE FEATURES 

Issue: Standard 2 requires that the original qualities or character of a building and its 
environment shall not be destroyed. The landscape and landscape features around a 
building are often important aspects of its character or that of the historic district in 
which it is located. It is incumbent upon an owner to ascertain the historic 
significance of all elements of an historic building and its site before making decisions 
about destroying or altering historic material. 

Even when development pressures within a neighborhood are intense, site features that 
help define a building's historic character must be retained as part of a certified 
rehabilitation. Those elements might include gardens, walls, fountains, pools, paths, 
site lighting, benches, or grading. 

Application: An early twentieth-century Mediterranean villa style house, individually 
listed in the National Register, had a formal garden, apparently conceived as an 
integral part of the total design (see illus. 1). The house had been vacant for over ten 
years and although the garden's architectural features were deteriorated and the 
planted areas were severely overgrown, much of the historic fabric remained. There 
were terraces at the front and rear of the building. The rear terrace had a simply- 
detailed pergola and steps down to a small walled garden with a fountain and an 
ornamental wall topped by an iron fence (see illus. 2). Symmetrical steps led from 
there to a long, narrow lawn (overgrown at the commencement of rehabilitation), at 
the base of which was a fountain against a masonry wall. 

In a recent rehabilitation that involved reuse of the house for rental apartments and 
development of the site with new low-rise apartment structures, the landscape 
features, both plant materials and architectural elements, were destroyed. In its 
denial of the project, the regional office, while commending the owner on his proposal 
for the rehabilitation of the house, stated: 

The walled garden, albeit in a neglected condition, was one of only a 
handful of formally designed gardens in the city that survive to the 
present day. The neighborhood was, in the last decade of the 19th 
century and the first decades of the 20th, a coherent and contiguous 
collection of medium to large scale urban mansions on small lots. Typical 
to these was a small, formally designed, often walled, garden either to 
the rear or to the side of the house. Today, few have survived. The 
imperative to save this significant feature was all the more important 
given this context. 



85-068 

The owner appealed, citing the following four points: 

1) The deteriorated condition of the garden structures and the overgrown site. 

2) The fact that the nomination to the National Register for the house did not 
mention the garden; therefore, it cannot be considered significant. 

3) The garden to the rear of the house was never visible from the public way, nor 
would it be after project completion. 

4) Certain elements of the garden — the basic configuration of a portion of the 
small walled garden, the urns, the balusters and some iron work will be reused. 

The owner also brought a photograph of the rear of the house after the garden area had 
been cleared as part of the rehabilitation effort, but before the new construction had 
begun. It was evident that nothing remained of the rear garden below the terrace; and 
that, in fact, most of the terrace had been demolished in preparation for construction of 
the new apartment structures (see illus. 3). 

The Chief Appeals Officer upheld the region's denial of the project, stating: 

Although the garden is not described in the documentation that was 
submitted to justify inclusion of the house in the National Register, as 
you pointed out during the appeal meeting, it was nonetheless a 
constituent element of the whole property that was nominated and 
accepted. The house and garden together constituted the complete 
resource. 

Furthermore, it is evident that the garden was conceived as an integral 
part of the total design for the house and was constructed at the same 
time as an appropriate setting to complement and enhance the imposing, 
romantically eclectic building. Although some of the features were 
deteriorated and the site was overgrown, the integrity of the original 
garden design had survived intact. 

The rehabilitation project, already well underway, will destroy all sense 
of the original garden design. No longer will the long vista exist from 
the terrace outside the house to the lower end of the site. Nor will one 
be able to step down through a small, enclosed garden, past a simply- 
detailed pergola, to a long, open lawn. The scale and design of retaining 
walls and balustrades, some topped with iron fences, will be lost. 

Prepared by: Susan Dynes, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



85-068 



IT 




1. Side view of the house, showing the retaining wall around the site and the front terrace. 




2. View of the rear of the house before rehabilitation began. There is a rear terrace 
with a pergola and a small walled garden with ornamental walls and an iron fence. 



85-068 




3. Rear of the house after garden was cleared but 
before construction began. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, DC. 20240 



Interpretin g 



the~Secretary of the Interior's 



"Standards tor Rehabilitation 



Number: 85-069 



Applicable Standards: 2. Retention of Distinguishing Architectural 

Character (conformance; nonconformance) 
6. Repair/Replacement of Deteriorated or 
Missing Architectural Features Based on 
Historical Evidence (conformance; 
nonconformance) 

Subject: FACTORS TO WEIGH IN EVALUATING DAMAGED/DETERIORATED 
BUILDINGS 

Issue: If a historic building is certified as "contributing to the significance of the historic 
district," this means that its physical characteristics are still able to convey historic, 
architectural, or cultural significance prior to rehabilitation and in spite of deterioration, 
damage, or loss as demonstrated by existing condition photographs. Part 1 certification 
of significance does not imply that historic building materials will be fully intact at the 
outset of rehabilitation; in fact, Part 2 work may involve repair or even total 
replacement of some particularly vulnerable historic material such as roofing, exterior 
wood cladding, wood window frames and sash, or interior plaster. On the other hand, if 
historic material that could have been repaired is unnecessarily replaced, Standards 2 and 
6 will not be met. 

An important factor to consider in evaluating the Part 2 work is the significance and 
integrity of the interior. The preservation of a significant interior that may include 
historic materials, features, finishes, spaces, or structural framing system may, in 
limited instances, serve to offset the documented need for extensive replacement of 
exterior material. In these select cases, the building can still make a positive 
contribution to the historic significance of the district and be certified for preservation 
tax incentives. 

Application: The first case is a two-story frame house with lap siding built ca. 1865- 
1870. Photographs of the exterior prior to rehabilitation revealed a combination of 
damage, deterioration, and previous alterations (see illus. 1). Specifically, lap siding had 
been inappropriately covered with stucco. A later front porch, nonsignificant front and 
rear additions, and an exterior metal staircase leading to the second floor had all been 
removed. Finally, the building's interior had lost the majority of its historic features due 
to earlier insensitive renovations. In spite of exterior and interior losses and change, the 
building had been certified as meeting Part 1 integrity requirements because the 
essential form and detailing was sufficiently intact to convey historic significance within 
the district. 

When the Part 2 application was submitted, rehabilitation work had already been 
completed. Before and after photographs of the exterior were limited to front, side, and 
rear elevations, with no detailed documentation evidence of deteriorated materials. The 
application stated that after removal of the nonhistoric stucco, the historic clapboarding 
was found to be deteriorated beyond repair due to moisture and termites. In 
consequence, all clapboarding was removed as well as the sheathing underneath. 



85-069 

At the same time, other historic wood features were removed and replaced, including 
roofing, window sash, sills, lintels, shutters, and wood trim (see illus. 2,3). Again, 
justification for replacement was based on extreme deterioration. When the State office 
reviewed the project, it recommended denial primarily based on undocumented 
replacement of exterior wood. Also, some of the replacement features were felt to be 
inappropriate, such as the heavy roof shakes. The region concurred with the State 
evaluation and the project was subsequently denied for nonconformance with Standards 2 
and 6. The denial letter from the Regional Director strongly emphasized the unnecessary 
introduction of new material: 

...replacing all weatherboards, all trim, shutters, all windows, all 
roofing materials, and adding new framing pieces for doors and 
windows, new brick stoops, new sills and thresholds, and new 
hardware have the cumulative effect of making this building appear 
to be a new house with some Colonial-style details... 

Because the owner felt that replacement of extensively deteriorated exterior wood 
cladding was justified, affadavits were submitted as the basis for a Part 2 appeal. 
These consisted of individual, signed statements from the project architect and a 
licensed structural engineer attesting to the severely deteriorated condition of the 
property prior to rehabilitation. No new photographs documenting deterioration were 
included. After careful review of the new information, the Chief Appeals Officer 
affirmed the Region's denial: 

...the affadavits...contain insufficient evidence to support your 
contention that the extent of the deterioration caused by moisture 
trapped behind the stucco and its subsequent removal was so 
widespread as to require complete replacement of the siding, window 
sash and frames, and the exterior wood trim... 

...I also find that the written record and the documentation clearly 
demonstrate that (the building) was a certified historic structure 
prior to rehabilitation. However, in consequence of your 
rehabilitation, everything now seen on the exterior of the building is 
new. Because of the inordinate amount of replacement material now 
visible. ..the structure has fallen below the acceptable level of 
integrity of materials and workmanship that were required for it to 
be designated a certified historic structure for purposes of the 
Federal tax incentives. Therefore. ..it is my determination that (the 
building) is no longer a certified historic structure. ..and that this 
decertification is not considered retroactive. 

In a second case, another "contributing" wood frame building, built ca. 1769, was 
rehabilitated by the present owner as a single family rental home. The building had 
been used historically for a variety of purposes, including a warehouse, residence, 
store, and post office. In the Part 2 application, the owner provided both general 
elevation photographs as well as detailed photographs of existing conditions, and 
ongoing and completed work (see illus. k , 5). Both exterior and interior work was 
photographically documented and submitted with a narrative explaining what was 
original, what was added later, what could reasonably be preserved, and what needed 
to be replaced. Because the owner's architect believed that exterior wood features 
were not repairable, extensive replacement of exterior work was already underway as 



83-069 

part of the rehabilitation. After review of the application, the State recommended 
approval; the Region, however, disagreed. 

Reviewing the same photographs of the exterior and interior, the Region felt that the 
building — although having had a long history of material replacement and alteration- 
still possessed a number of early features. The significant wood features cited were 
"rafters, joists, and other structural members, some sash, window and door frames, 
doors, and much early wall sheathing and clapboarding." In denying the project for 
nonconformance with Standards 2, 5, and 6, the Region stated: 

While in some instances replacement of materials may have been 
warranted due to the degree of deterioration, such wholesale 
replacement appears unjustifiable on the basis of submitted 
documentation and constitutes an irretrievable loss of original 
historic fabric. ..Photographs submitted indicated that many original 
features could nave been spliced, patched, treated with consolidants, 
or in other ways retained, thus preserving original and distinguishing 
features. As the building presently stands, there is almost no historic 
material in place. 

The owner felt that his rehabilitation met the Standards and the denial was 
subsequently appealed. On appeal, the Chief Appeals Officer agreed that there had 
indeed been extensive loss of exterior wood features in the rehabilitation, but 
disagreed as to their relative historical significance, particularly when weighed 
against unusual existing structural components and interior materials and features 
dating from the early 19th century. This included original ceiling rafters, cupboards, 
paneling, and fireplaces. Of importance in the appeal were photographs documenting 
the fact that the highly significant interior was preserved in the rehabilitation (see 
illus. 6, 7). Most important, although replacement of historic exterior wood was 
extensive, the clapboarding was found to be machine-sawn from the early 20th century 
and therefore not as significant as the Region had believed. 

I agree with the Regional Director's assessment of the historic and 
architectural significance prior to rehabilitation. Despite its deteriorated 
and altered condition, its character as an 18th century structure was 
evident in its location and setting on the Meeting House Green, in its 
form, and in such particulars as its post-and-beam construction... 

Careful examination of the photographs of the completed work submitted 
for this appeal reveals that considerably more of the historic building 
remains than was thought by the regional office. Virtually all of the 18th 
century framing that survived the earlier fire has been preserved intact; 
this framing gives the building its form and is an important component of 
its architectural significance. Inside the building are exposed posts, joists 



85-069 

and summer beams, and early 19th century mantels, panelling and 
cupboards on the chimney walls of four rooms, door and window frames, 
and several doors that are all original elements or later additions that 
have acquired significance. The further documentation of the completed 
work demonstrates high retention of interior features. 

Prepared by; Kay D. Weeks, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 




85-069 



1. Front and side elevations of a ca. 1865- 
1870 wood frame building prior to 
rehabilitation. Stucco had been applied over 
the exterior wood at a later date and had 
caused rotting and termite infestation of 
historic wood. The building was certified as 
meeting Part 1 integrity requirements in its 
deteriorated and damaged condition. 





2, 3. The same building shown after rehabilitation is essentially new construction. Rather than 
targeted replacement of deteriorated materials, the owner replaced all of the siding, roofing, windows, 
sills, shutters, and trim. Some of the replacement features, such as the use of thick, cedar shakes on 
the roof and side porch were considered inappropriate. The owner was denied Part 2 certification on 
appeal. As a result of material loss during rehabilitation and the earlier loss of interior features and 
spaces, the Part 1 certification was also withdrawn because the building could no longer meet integrity 
requirements. 



85-069 




'v*jM\jSm 



4. A ca. 1769 building was certified in the Part 1 application in its existing condition, which involved 
extensively deteriorated exterior wood clapboarding, sheathing and window sash. On the interior, some 
original framing members were intact, while others were repaired or replaced. 




5. Completed exterior work shows the extent of replacement of deteriorated exterior wood 
materials and features. All siding and sheathing was replaced with new wood. Window sash and 
frames are also new. The applicant documented areas that needed to be replaced because of 
extensive deterioration as well as those portions, such as the cornice molding, that could be 
retained and preserved. 



85-069 




6. An early pegged-braced structural system, fireplace with bee-hive oven, and cupboards are shown. 
If the extant, significant interior had not been factored into the evaluation to offset extensive loss of 
exterior materials, overall preservation requirements for Part 2 would not have been satisfied. 




7. The same room shown above after completion of the work. On appeal, it was concluded that the 
building's highly significant interior, including materials, features, spaces, and an early structural 
system had been identified prior to rehabilitation, then carefully retained and preserved. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 20240 



Interpreting 



the~Secretary of the Interior's 



Standards tor Rehabilitation 



Number: 85-070 

Applicable Standards: Standards for Evaluating Significance With 

Registered Historic Districts (36 CFR 67.5 (2)(e) 

Subiect: REMOVING FALSE FRONTS OR NONHISTORIC SURFACE COVERINGS 
PRIOR TO REHABILITATION 

Issue: As part of the 1950's drive to clean-up, or "modernize" shopping and residential 
areas, metal false fronts were often attached, or nonhistoric surface coverings 
directly applied to historic building facades. When a Part 1 evaluation of significance 
is requested prior to rehabilitation and a false front or nonhistoric surface covering is 
in place, the need for removal will differ depending upon the type and extent of the 
obscuring covering. Two basic types of covering exist: 

(1) A false front or screen covers up a historic building's facade, concealing the form, 
materials, design, workmanship, and historic relationship to other buildings in the 
district. In past administrative practice, removing a false front was considered to be 
part of the rehabilitation work itself and thus assessed in the Part 2 evaluation for 
conformance with the Secretary of the Interior's "Standards for Rehabilitation," 
particularly Standards 2 and 6. Now, in accordance with the revised regulations (36 
CFR 67 - March 12, 1984) at least a portion of the false front or screen must be 
removed prior to rehabilitation in order to evaluate the integrity of the historic 
building. After the historic integrity is established through evaluation, the false front 
or screen will generally need to be removed totally in order to receive final Part 1 
certification. 

(2) On the other hand, when a nonhistoric surface covering (such as aluminum or vinyl 
siding, permastone, or asbestos siding) has been directly applied over historic wall 
surfaces, removal of that material may not always be necessary for Part 1 
evaluation. A nonhistoric surface material, unlike a false front, usually does not 
totally obscure a building's significant form, features, and detailing. When a building's 
historical significance is conveyed through other surviving characteristics of the 
exterior of the building (such as its roof, cornice, unusual windows, chimneys, 
ornamentation, etc.), then a Part 1 certification of significance may be given with the 
nonhistoric surface covering left in place. The covering may simply be retained in 
rehabilitation; alternatively, it may be removed by the owner. 

In summary, for both types of covering, Part 1 certification will be issued only when 
enough of the historic building is visible to classify the building as contributing to the 
historic district even if the proposed rehabilitation were not completed for some 
reason. 

Application: Part 1 certification was requested for a two-story masonry building in a 
historic district. A photograph of the 1908 department store (see illus. 1) was 
submitted together with photographs of the existing appearance. In its current 
condition, however, it did not convey historic, architectural, or cultural 



85-070 



significance because an aluminum false front had been attached in the 1950s, hiding 
the facade as well as wrapping around both sides of the building. Enamelized metal 
squares had also been affixed to the side elevations. The rear of the building was both 
visible and apparently intact, but had no particularly distinguishing features (see illus. 
2,3,4) 

Even though the storefront had been altered in an earlier renovation prior to 
attachment of the false front, there was some evidence that the second story of the 
department store remained relatively intact underneath. Because a 16" gap had been 
left between the metal screen and the store's facade it was possible to look out the 
original window and see some of the masonry detailing behind the screen. This 
suggested that the building might retain enough integrity to meet overall requirements 
for Part 1 certification. 

Consequently, the owner was notified by the Region that at least a portion of the false 
front would need to be removed in order to evaluate the historic facade to see if it 
possessed sufficient integrity for Part 1 certification. In response, the owner 
informed the Region that the scope of rehabilitation would be limited to interior work, 
and the building's exterior would remain "as is," in its covered condition. As a result, 
the building was not issued "certified historic structure" status; however, if ownership 
were to change, a new owner could reapply for Part 1 certification of significance. 

In a second case, an owner submitted a Part 1 and Part 2 application with photographs 
of a 2 1/2 story, hip-roofed, frame and masonry building in a tree-lined district of 
similarly scaled residences. Photographs and a narrative explained that the building 
had been covered with a concrete veneered covering, and that the wood window sash 
and shutters had also been replaced with new aluminum "features" (see illus. 5). It was 
acknowledged in the application that these changes to the building did not contribute 
to its overall architectural appearance and historic integrity. Documentation also 
included several photographs of the interior showing raised paneling, parquet floors, 
tiled fireplaces, and intricate plaster cornice moldings and, in fact, the application 
emphasized the interior's significance. 

In the Part 1 evaluation, the reviewer initially expressed some concern over the 
concrete veneer covering historic materials, but concluded that other surviving 
exterior features such as building's form, its roof—roofing materials, dormers, 
chimneys and cornice— and an elaborately detailed portico satisfactorily conveyed the 
building's architectural significance in relationship to the district (see illus. 6). 
Removal of the nonhistoric surface covering was thus not required for Part 1 
certification to be issued. This decision would have been made even if interior 
materials, features, and spaces had not been significant and intact. 

Prepared by: Kay D. Weeks, TPS 



These bulletins are issued to explain preservation project decisions made by the U. S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



8,5-070 




O CHS B.RO S. 



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1. Early 1900s photograph of 
the Ochs Building shows the 
storefront in its historic design 
prior to a series of renovations, 
the last of which totally 
obscured the facade. 






2, 3, k. The department store shown as 
submitted for Part 1 evaluation, with a 
false front obscuring the primary 
elevation and enamelized metal squares 
covering the secondary elevation. A 
photograph of the rear elevation showed 
a portion of the building's historic 
material that nad not been obscured. 
This elevation, however, was not of any 
particular architectural or historic 
significance. 



Z5-Q7Q 



5. A photograph of a portion of the 
primary facade reveals a highly 
decorative porch, but also shows the 
nonhistone concrete veneer, and 
aluminum sash and shutters. 





6. The building is shown here on the right in relationship to another building in the district. 
Although the historic wood sheathing has been obscured with formstone that is heavy and gray 
in appearance, the surviving physical characteristics of the rest of the building were sufficient 
to convey historic and architectural significance. This includes the roof shape and materials, 
and a decorative cornice and portico. Part 1 was issued. In the rehabilitation, the concrete 
veneer was simply patched and retained as part of overall work. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department ot the Interior 
Washington, D.C. 20240 



Interpreting^ 



fie~Secreta r v ot the Interior's 



Standards tor Rehabilitation 



Number: 85-071 



Applicable Standards 2. Retention of Distinguishing Architectural 

Character (nonconformance) 
9. Compatible Design for New Additions 
(nonconformance) 



Subject : PROPOSED ROOFTOP ADDITION ON BUILDING WITH A DISTINCTIVE 
CORNICE 

Issue : Rooftop additions can meet the Secretary of the Interior's "Standards for 
Rehabilitation" if they are inconspicuous within the district or neighborhood and do 
not alter the historic character of the building. If a building has a distinctive profile 
against the skyline, a profile created by turrets, ornamental cornices or other 
character-defining roof features, it may be very difficult to design a rooftop addition 
without either destroying significant material or radically altering the appearance of 
the building. 

Application : A nine-story commercial office structure, built in 1910-11, determined 
to be eligible for individual listing in the National Register, was to be renovated for 
continued use as offices and commercial space (see illus. 1 and 2). Situated on a 
highly visible corner property, the building is distinguished by its U-shaped plan, 
distinctive storefronts, elegant brick and terra-cotta detailing and most particularly 
by an elaborate projecting terra-cotta cornice and parapet. 

The owner's proposal to construct two additional stories atop the building (see illus. 3) 
was denied certification by the regional office, which cited the "negative impact on 
the historic character of the building" of such an addition. The design of the rooftop 
addition, the denial letter further stated, "will compromise the historic character of 
the building by appearing as a historic component; the building's original scale will be 
altered, and the prominent cornice will be compromised, all violating Standards 2 and 9." 

Upon appeal by the owner, the denial was affirmed by the Chief Appeals Officer, who 
noted that "the two-story addition... would extend to the plane of the wall, thereby 
drastically reducing and weakening the prominence of the cornice." The "marked 
appearance of the cornice against the sky," he continued, is "virtually unique" in the 
city, and is the "overriding character-defining feature of the building." 

In reaching his decision, the Chief Appeals Officer noted the extensive research into 
the history of the building undertaken by the owner and presented at the appeal 
meeting. This information included the original structural steel drawings, which 
depicted an eleven-story building rather than a nine-story structure. These drawings 
indicated that the top two floors of the structure would have been constructed out to 
the facade line, much in the manner of the proposed addition. No elevation drawings 
were found, but surviving physical evidence, original promotional material, and 
testimony taken in a lawsuit involving the original owners also supported the claim 
that the building was originally designed for eleven rather than nine stories. 



85-071 

The Chief Appeals Officer acknowledged the evidence presented by the owner as 
satisfactorily establishing "that the original builders contemplated an eleven-story 
edifice rather than the nine-story building that was constructed and exists essentially 
unaltered today." He noted further that "the additional two stories, had they been 
built, would have been constructed above the cornice." He concluded, however, that 
the information, while very interesting, had "little relevance to the matter under 
consideration; what concerns us here is that which was built and embodies historic 
identity.... The fact is that the building was built as it was and its historic character 
for seventy-five years has been largely determined by the appearance of its cornice 
unencumbered against the sky." Because the proposed addition would have diminished 
that appearance, it would not have preserved the historic character of the building, 
and was consequently denied certification. 

Prepared by: Sharon C. Park, AIA, and Michael 3. Auer, Ph.D. 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



85-071 



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85-071 




3. The proposed rooftop addition, like other designs submitted, would have 
obscured the appearance of the character-defining cornice against the sky. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department ot the Interior 
Washington, DC. 20240 



Interpreting^ 



tFie~Secreta r v of the Interior's 



"Standards tor Rehabilitation 



Number: 85-072 



Applicable Standards: 6. Repair/Replacement of Deteriorated or 

Missing Architectural Features Based on 
Historical Evidence (nonconformance) 
9. Compatible Contemporary Design for New 
Alterations/ Additions (nonconformance) 



Subject: PRESERVING DISTINCTIVE SIDE AND REAR ELEVATIONS 

Issue : Attaching a new exterior addition usually involves some degree of loss to an 
external wall or wails. For this reason, it is generally recommended that an addition 
be constructed on a secondary side or rear elevation—as opposed to a primary 
elevation—where significant materials and features are less apt to be present. 

There are cases, however, where side or rear elevations are architecturally detailed; 
where they display either a distinctive individual plan or a plan characteristic of 
buildings in the neighborhood; where they were traditionally highly visible within the 
block; or where they are of special historical significance. In these instances, the 
distinctive features on a side or rear elevation also need to be retained and preserved 
in rehabilitation, i.e., not damaged, destroyed, or hidden. If materials or features 
judged to possess significance are damaged or destroyed in the process of 
rehabilitation the intent of Standards 6 and 9 will not have been met. 

Application: A late 19th c. 3-story, 3-bay brick rowhouse was determined to 
contribute to the historical significance of a small-town historic district. The building 
was typical of other Victorian-era brick townhouses in the district with its Italianate 
doorway, brackets, dentil work, and stone steps. Also characteristic of many buildings 
in the district, there was a brick two-story kitchen wing with a small second-story 
porch that featured a decorative balustrade on the rear of the building (see illus. 1, 
2). The interior was both significant and intact; photographs documented features 
such as a mahogany balustrade, marble fireplace, plaster ceiling trim, and original 
doors and trim. 

Rehabilitation of the building essentially involved work to convert the residence into a 
dress shop. The owner felt that the existing interior space was inadequate for the 
retail operation, and, as a result demolished the historic rear ell and two-story porch 
preparatory to building a much larger addition in its place (see illus. 3). 

When the Part 2 application was reviewed by the State, denial was recommended. 
Several work areas were questioned, but loss of the rear addition and porch in order to 
construct a new, large scale commercial wing was the primary reason for denial. 
Standards 2, 9, and 10 were cited. The regional office agreed with the State's 
assessment, and also cited Standard 6. The denial letter, emphasizing the loss of 
fabric on a distinctive rear elevation, stated in part: 



85-072 

...demolition of the rear wing and second-story porch has resulted in loss of 
historic fabric. In the case of the porch, there was a loss of skilled 
craftsmanship as well. In the case of both the porch and wing, the historic 
rowhouse configuration (designed to supply more light, air, and space than 
was available from the main block alone) has been destroyed. The 
replacement design has a non-residential scale and appearance. No 
evidence of deteriorated conditions has been given to justify the 
demolition... 

In the appeal, the owner explained that in order for the residence to function as a 
shop, certain changes had been necessary. The interior needed to be expanded and, to 
do so, an extensively deteriorated, and essentially nonsignificant porch had been 
removed. To substantiate their claim, a letter was submitted by the architect 
certifying that the rear brick kitchen wing and two-story porch could not be 
preserved; however, no photographs of deterioration and structural failure were 
provided. 

After carefully evaluating the facts of the case, the regional office's denial was 
sustained by the Chief Appeals Officer. Citing loss of historic material as well as a 
permanent change to the rear of the building, the decision was further explained in a 
final letter to the owner: 

The historic rear wing and second-story porch were demolished due to 
alleged severe structural deterioration; the extent of deterioration, 
however, was not substantiated in the course of the meeting. Furthermore, 
the design of the new rear wing is not compatible with the building or the 
district. In mass, proportion, and scale it differs drastically from what was 
there before and stands as an intrusion in the texture of the neighborhood, 
the character of which can be appreciated from the rear parking lots as well 
as from the street. The addition of this wing also resulted in significant 
change in the spatial arrangement of the first floor interiors. Accordingly, 
despite some exemplary preservation of interior details, I have found that 
the work does not satisfy the "Standards for Rehabilitation." 



Prepared by; Kay D. Weeks 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



83-072 





77 






I, 2. The 3-story brick rowhouse, front and rear elevations, prior to conversion 
into a dress shop. Although many rear elevations are not particularly distinctive, 
this one featured a second story gallery and brick kitchen wing that were 
characteristic of the rear elevations of other residences in the district. 
Demolition of the wing and gallery preceded construction of a massive new 
addition that interrupted the former visual unity of the neighborhood. 




3. Completed work, rear elevation. The project was denied, largely based on 
demolition of the rear wing and porch and construction of a large addition that 
changed both the exterior form and interior plan. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 20240 



Interpreting 



the~Secretarv of the Interior's 



Standards tor Rehabilitation 



Number: 85-073 

Applicable Standards: 2. Retention of Distinguishing 

Architectural Character (conformance) 
k. Removal of Later Non-Significant 
Alterations/Additions (conformance) 

5. Sensitive Treatment of Distinctive 
Features and Craftsmanship (conformance) 

6. Repair/Replacement of Deteriorated 
or Missing Architectural Features 

Based on Historical Evidence (conformance) 

Subject : ALTERNATIVE REHABILITATION TREATMENTS FOR LATER 
NON-SIGNIFICANT ADDITIONS 

Issue: The Standards generally encourage the retention of later additions to historic 
buildings. Such additions often have acquired significance in their own right because 
they provide evidence of the historical evolution of the building or because they are 
important examples of an architectural style. 

Circumstances under which a later addition may not contribute to the significance of a 
historic structure include: 1) a later addition that is less than fifty years old; 2) a later 
addition that is not a fine example of an architectural style, or does not exhibit 
significant character or fine workmanship; 3) a later addition that does not contribute 
measurably to the National Register-determined period of significance of the building 
or district; k) a later addition that is so badly deteriorated that its replacement would 
constitute a level of "reconstruction" not required in a rehabilitation; and 5) a later 
addition that obscures earlier significant features. 

Additions to historic structures that meet any of these conditions may be treated in a 
variety of ways. Rehabilitation options include retention of the later addition, removal 
of the addition to reveal restorable features underneath, replacement with new features 
of a compatible new design, or, if adequate historical documentation exists, 
replacement with an accurate duplication of original features. 

Assessing the significance of later additions requires careful professional review, and 
must always be done on a case-by-case basis. Removal of significant later features can 
result in denial of certification of a project. 

Application No. 1 ; A six-story structure, individually listed on the National Register as 
well as in a National Register historic district, and erected in 1906 as a private 
residence and hotel, was rehabilitated for use as an office building (see illus. 1). The 
facade, exhibiting stylistic elements derived from the French Renaissance, was faced 
with a high quality brick veneer trimmed with brownstone, and the building was topped 
with a graceful "mansard" roof. Over the years, however, the building had undergone 
some stylistic changes and additions, the most notable being the construction of an Art 
Moderne carrara glass storefront on the first floor to accommodate a bar, as well as the 



85-073 

addition of a copper marquee (c. 1928 according to the application) over the hotel 
entrance, and extensive remodeling of the interior. The rehabilitation proposal called 
for the removal of the Art Moderne storefront, the bar interior, and the marquee, and 
reconstruction in their place of the original 1906 first-floor facade (see illus. 2). The 
regional office of the National Park Service denied certification because the 
cumulative effect of the proposed work would result in a rehabilitation that did not 
conform to Standards 2, 4, 5 and 6 of the Secretary of the Interior's "Standards for 
Rehabilitation." This decision was based largely on the proposed removal of the bar 
storefront and its interior which the region judged to date from the 1930's, and removal 
of the copper marquee (although other issues including interior fabric removal and its 
reconfiguration were cited in the denial letter). The regional office had assessed all of 
these additions to be character-defining features of the structure, and as such should be 
retained in the rehabilitation. 

Upon appeal, the denial of the regional office was overturned, in part because of the 
availability of new information at the appeal meeting, including photographs that 
clearly showed earlier unsympathetic remodelings had destroyed all of the bar interior, 
documentary evidence that the Art Moderne storefront had been constructed in the 
1940's, and assurance that the rehabilitation would retain all historic fabric still extant 
on the interior. The project, now already in progress, was given preliminary 
certification, and in a letter explaining his decision, the Chief Appeals Officer 
emphasized that he strongly concurred with the policy espoused by Standard 4 that 
encourages retention of those later additions that have acquired significance over 
time. But in this case, the owner had 2 valid options— either to retain the existing 
storefront or because of the existence of detailed drawings of the original facade, to 
restore that facade: 

...each instance has to be judged on its own merits, and I find that this 
Art Moderne storefront is not of exceptional architectural or historical 
significance; it is less than 50 years old, is not mentioned in the National 
Register documentation as possessing exceptional importance. ..and is not 
architect-designed. Furthermore, because of the existence of the original 
drawings, restoration of the 1906 facade was also an acceptable approach 
in accordance with Standard 6. The unusually accurate substantiation of 
the original design was a major consideration on this point. 

The fact that nothing remained of the bar interior provided further 
argument favoring restoration of the original facade. I feel that the 
copper marquee, like the storefront, is also not of exceptional 
significance and may be retained or removed at your discretion. 

Application No. 2: Another project involved rehabilitation of two residential 
properties for apartment use. Originally constructed in the early part of the 
nineteenth century as multi-family housing for mill workers, these buildings had been 
certified as contributing to the significance of the historic district in which they 
were located. The houses were situated side-by-side, and nearly identical in design 



85-073 

and floor plan. They were of frame construction, two and a half stories, and six bays 
wide with a gabled roof (see illus. 3-4). Each house had a later addition of a wooden 
porch that stretched across the length of its facade. Rehabilitation work on the 
properties was extensive as the houses had fallen into disrepair through lack of 
maintenance. 

Although the State Historic Preservation Office had recommended approval of the 
rehabilitation project, the regional office of the National Park Service denied 
certification on the basis that the completed project violated Standards 2, 4, 5 and 
6. As in the example discussed above, the region felt this rehabilitation did not 
conform to the Standards due in part to removal of the later additions — in this case, 
the porches (see illus. 5-6). The region's denial letter stated "these front porches 
were significant to each house as a later addition (estimated to be from 1900 or 
earlier) and were significant collectively as a phenomenon within the district." 

The owners appealed the regional decision, because they felt the rehabilitation met 
the Standards. At the appeal meeting the owners defended removal of the porches 
on the basis that the porches were poorly constructed of inappropriate materials 
which at the time of the rehabilitation were found to be too deteriorated to repair, 
and not of sufficient quality or workmanship to retain. Most importantly, however, 
research had revealed the fact that the porches in question were first depicted on 
the Sanborn insurance map of 1926, but did not yet appear on the map of 1914. Thus, 
the maps clearly showed that the porches had been built in the twentieth century, 
outside the period of significance of the district. 

After reviewing all the facts of the case, the Chief Appeals Officer agreed with the 
owners that the rehabilitation met the Secretary of the Interior's "Standards," and 
overturned the denial issued by the regional office. In doing so, he stated that the 
primary significance of these properties lay in their exterior form and details, and 
that these character-defining features had been preserved and restored in the 
rehabilitation. Had the porches been in a better state of repair, their retention 
would also have been an option. He further explained his decision to the owner, 
saying: 

In its denial letter the regional office stated that removal of the front 
porches was in violation of the Secretary of the Interior's Standards, 
because these porches had not only acquired significance as later 
additions but also were significant collectively as a phenomenon within 
the historic district. However, from information you presented at the 
appeal meeting, we can now date the porches between 1914 and 1926, a 
period outside the significance of the historic district as a nineteenth- 
century mill community. 

Thus, for both of these projects featuring later additions that did not contribute to 
the significance of the historic structure or the district, there were the four 
alternative rehabilitation treatments outlined in the introduction from which to 
choose. One option, in both cases, might have been to retain the later addition. But 



85-073 

another option in accordance with the Standards, and the one selected for both 
projects, was restoration. In the first example, restoration of the 1906 facade was 
made possible because of the discovery of the existence of the original architect's 
drawings. In the second project, restoration was made possible because discovery of 
two Sanborn maps proved that the porches had not been constructed until the 
twentieth century, and therefore did not contribute to the nineteenth century period 
of significance of the historic district in which the houses were located, and as such, 
could be removed. 



Prepared by; Anne Grimmer, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



> 




85-073 



1. The 1906 hotel before rehabilitation. 
Note the Art Moderne facade and copper 
marquee on the first floor. 




2. During rehabilitation into an office 
building the first floor is being recon- 
structed according to the original 
architectural drawings. 



85-073 




■<.'.' 



3-4. The two houses before rehabilitation. Because the porches were added after 
the historic district's period of significance, their removal was one option. 




85-073 




5-6. The two houses after rehabilitation, 
their porches removed to reveal the original 
early nineteenth-century character. (Twelve 
over twelve window replacement was based on 
remaining original sash still extant in 
several of the third floor windows.) 




Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
US Department of the Interior 
Washington, DC. 



Interpretin g 



th~e~Secretarv of the Interior's 



Standards tor Rehabilitation 



Number: 85-074 



Applicable Standards: 



2. Retention of Distinguishing Architectural 

Character (non-conformance). 
9. Compatible Design for New Additions 

(non-conformance). 



Subject : ROOFTOP ADDITIONS 

Issue : Rooftop additions proposed for larger urban buildings raise certain preservation 
issues. First, there is the concern over material loss ~ to what extent significant 
historic features such as cornices will be altered and how much of the roof system and 
the building's structural framework will be altered, damaged, or destroyed. A second 
preservation issue is the visual impact of the addition on the historic character of the 
building. The size, scale, material, color and detailing of the proposed addition may 
individually or collectively impact other distinctive historic qualities of the building. 
Finally, an addition is often designed so as to appear to be an important and integral 
part of the historic design ~ a treatment which can compromise the historic character 
of the structure and as a result preclude the project from obtaining certification of 
rehabilitation. 

Application : A former City Hall was recently rehabilitated for use as private offices 
(see illus. 1). The building is located in a downtown historic district that includes 
many financial and institutional buildings of the early 20th century, typically k to 10 
stories in height. Early in the history of the building, a rooftop addition had been 
constructed, set off to one side. Though set back from the facade, it was clearly 
visible diagonally from across the intersection as well as from down the street. The 
poorer quality workmanship and material and the fact that the electrical, mechanical 
and plumbing systems were independently designed led to the National Park Service 
determination to approve its planned removal. 

The owners proposed construction of a new one-story addition running the full depth of 
the building yet set back along the side elevations from the historic roof balustrade 
(see illus. 2). On the front, however, the proposed addition would create a highly 
visible 3 bay penthouse, set along the same plane as the front of the building and 
detailed to match. When the plans were reviewed by the National Park Service a 
determination was made that the addition precluded the project from meeting 
Standards 2 and 9. 

Problems with the proposed addition included its prominent location on a major facade 
and the detailing, which made the addition read as an integral part of the historic 
structure. The detailing emulated the original and along with its form and location 
resulted in the addition becoming a strong new design element on a significant facade 
— an element which also took on an instant "historic" look. While it was restrained in 
size and scale in proportion to the historic building, it altered the building's historic 
character. The building had a distinct form which would be changed by the addition of 



85-074 

such a prominent penthouse. Furthermore, the historic cornice no longer would be the 
termination of the historic building in design, now having to share that role with the 
proposed addition. 

In the end, the financial infeasibility of any rooftop addition precluded its 
construction. 



Prepared by; Charles E. Fisher, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S. 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



85-074 




1. This former City Hall, shown here in a 1925 photograph, has changed little over 
the years on the exterior with the exception of an old rooftop addition off to the 
left. The building has a prominent corner location and is highly visible not only at 
the intersection of two busy thoroughfares but also from down the streets as well. 



85-074 




2. The proposed penthouse addition with the three bay portion across the front was 
determined not to meet the Standards for Rehabilitation. The change in the form 
of the building; the conscious attempt to tie the addition to the historic building 
through use of replicative detailing; and the alterations to the historic roof 
balustrade, were all factors cited by the National Park Service. 



Technical Preservation Services 
Preservation Assistance Division 
National Park Service 
U.S. Department of the Interior 
Washington, D.C. 



Interpreting 



the Secretary of the Interior's 



Standards tor Rehabilitation 



Number: 85-075 



Applicable Standards: 2. Retention of Distinguishing Architectural 

Character (nonconformance). 



9. Compatible Design for New Alterations/ 
Additions (nonconformance). 



Subject : ELEVATED PEDESTRIAN BRIDGE AS PART OF A REHABILITATION 

Issue : Elevated pedestrian bridges have become popular urban features in downtown 
developments. Networks of pedestrian bridges, often referred to as "skywalks" or 
"pedways," may be found in numerous cities to protect pedestrians from inclement 
weather and ease safe movement between buildings. 

Pedestrian bridges, however, pose particular problems for historic buildings; they are 
difficult to integrate into a rehabilitation without altering the character of the 
historic resource. Standards 2 and 9 address the issues of retaining character-defining 
features and materials as part of an overall rehabilitation. When a primary elevation 
is partially obscured by a large, horizontal new element that penetrates the historic 
resource or complex, it is generally the case that the historic character of that 
resource is severely impacted. 

In the following two examples denial of certification resulted from the proposal to 
incorporate a "pedway" into the overall rehabilitation. These elevated bridges had a 
negative impact on the individual buildings as well as the district in which they were 
located. 

Applications : A rehabilitation proposal called for the conversion of a group of eight 
historic row warehouses into an interconnected mixed-use complex of shops and 
offices. The buildings are located in a downtown urban area that has experienced 
substantial demolition and subsequent new office construction. The warehouses 
comprise the entire historic district located on two blocks and divided by a road (see 
illus. 1 and 2). Across from the historic district is a modern office complex and public 
plaza. The road between the two is a major traffic artery and the city has proposed a 
pedestrian bridge over this road as part of a network of downtown bridges. The 
developer wished to incorporate this bridge into the new complex to provide a 
convenient, safe entry for office workers and shoppers. The developer determined 
that the bridge would help ensure the financial success of this project. 

This tworblock historic district is characterized by large, solid, five-story brick 
warehouses that follow a major transportation artery. In fact, one of the historic 
buildings is angled at its midpoint to follow this road, thus creating a vista that is an 
important aspect of this grouping of buildings. The formation of two distinct block of 
buildings separated by a road is also a character-defining feature of this unique 
grouping of row warehouses. The bold scale, the articulated warehouse detailing, and 
the continuous panoramic vista of the two separate groupings of buildings are all 
important aspects in establishing the character of this historic district. 



The developer, sensitive to the exterior character of the warehouse buildings, 
proposed to leave the existing exteriors unaltered except for the replacement of lost 
features such as storefronts. As such, his proposal for the elevated "pedway" would 
not penetrate the original warehouses, but would enter the complex through a 
proposed new infill structure located over the site of the road which divided the 
district (see illus. 3). The design for the new "pedway" would be a thin steel box- 
frame truss and open on the sides. 

The State and the regional office, however, determined that both the pedestrian 
bridge and the new infill construction would so alter the character of the historic 
resource that the overall project should be denied. On the issue of the proposed 
"pedway," the region's denial letter stated the following: 

The proposed changes would impact the character of the row as a 
series of structures which are significant for their cohesive 
appearance.... The angle at which the buildings and the street 
bend midway through the row already serves to distinguish the 
row into a series of two sequential experiences. Interposing the 
pedway addition would destroy the way this row of buildings is 
experienced. The pedway is therefore incompatible with the 
existing row which violates Standard 9 and it would destroy the 
distinguishing qualities of the site and the environment in which 
these buildings are located thus violating Standard 2. 

The owner appealed the regional decision stating that the bridge was of lightweight 
construction, that it would not intrude visually, and that the industrial character of 
the bridge was in keeping with the industrial character of the buildings. The Chief 
Appeals Officer, however, agreed with the State and the region that the presence of 
this bridge, or any bridge, along this primary elevation would severely impair the 
historic character of the buildings and the district. In his letter which sustained the 
region, the Chief Appeals Officer concluded that: 

The bridge would bisect the district, and even though the 
structural members would not be glazed on the sides, this bridge, 
or any bridge, would be a major intrusion; for it would interfere 
with the distinguishing character of the cohesive groupings of 
row warehouses, the significance of which qualified the district 
for entry in the National Register of Historic Places. 

In a second case, a 20-story office building, both individually listed in the National 
Register as well as being within a registered historic district, was scheduled for 
conversion into shops and 155 apartments. The design of this early 20th century 
building followed the classic approach of a formal limestone base three stories high, a 
block or body of brick constructions with regularized window openings for 12 floors 
and finally a capping of several floors in a lighter brick under an elegant copper 
dormered "mansard" roof (see illus. 4). Located on a corner across from a large open 
park, the two street elevations were primary facades of equal detail and articulation. 

As part of the rehabilitation, the owner wished to provide parking for his tenants. The 
building had no surface parking on its own site, but the developer owned a new building 
a block away where secured parking and a health club would be available for use by 
the tenants. As the neighborhood was still in transition after a period of decline, the 



85-075 

owner felt that the only way to market his apartment building sucessfully was to 
guarantee his tenants 2k hour security, not only in the building, but from the parking 
garage via a pedestrian bridge. As the lower two floors of the building were to house 
offices and shops, the entrance of the proposed pedestrian bridge at the third floor 
provided a convenient lobby and entry point for tenants as well as serving as one of 
several required fire exits from the complex. The owner had made arrangements with 
the city to lease the airspace on an annual basis. 

The owner's architect detailed the proposed pedestrian bridge to fit inside the arched 
fanlight at the third floor in order to reduce the loss of historic materials (see illus. 
5). Any sash, framing or transom panels removed would be stored in the building for 
reinstallation at a later date if the pedestrian bridge were ever removed. 

The State and regional offices, however, were extremely concerned that the 
pedestrian bridge, located on a formal elevation of the building and only one bay away 
from the front entrance would drastically alter the appearance of the historic 
resource (see illus. 6). The project was denied certification and the owner appealed 
the decision. The Chief Appeals Officer agreed with the denial, further stating: 

The proposed pedestrian bridge is an inappropriate and 
incompatible attachment to the primary facade of this 

architecturally significant building To interfere with the view 

of the building and adjacent structures by floating a bridge above 
other historic buildings and the street and insert it into a 
nomumentally organized and carefully detailed facade would 
damage the architectural concept and diminish the historic 
character of the resource and adjacent buildings. The new 
feature would be dramatic and conspicuous, not subordinate to 
the historic structure; and the traditional views of the 
streetscape and the building would be distorted. 

Although I appreciate the desire for functional and service 
amenities for your tenants, I am still unable, in view of the 
whole, to see this proposed bridge as consistent with the historic 
character of this important building. Therefore, it is my 
judgement that the bridge will have to be deleted if the desired 
certification is to be gained. 

In each of these cases, the pedestrian bridge was considered by the owners as a 
critical marketing device. In both cases, however, the pedestrian bridge as a major 
new design element on a primary facade. Regardless of other issues raised as part of 
the denial, the "pedway" alone would have resulted in denial of certification. 

Prepared by: Sharon C. Park, AIA, TPS 



These bulletins are issued to explain preservation project decisions made by the U.S 
Department of the Interior. The resulting determinations, based on the Secretary of 
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the 
unique facts and circumstances of each particular case. 



85-075 




1. Case No.l: This view is looking south along the major street. Note the bend in the 
warehouse row as the buildings follow this road. This two block row of eight buildings 
is the last remaining row of industrial warehouses in the city. 




2. This view of a portion of the historic district is looking north. Note the road which 
divides the district into two blocks. This is the site of the proposed new addition and 
"pedway." 







3. This artist's rendering, looking south, shows the proposed "pedway" connecting a 
public plaza across the street to the renovated warehouses. This new horizontal 
element, visually intrudes on the historic panoramic vista of the warehouses and was a 
cause for denial of certification. The glass enclosure over a historic street was a 
separate cause for denial. 



85-075 




k. Case No. 2: This 20-story building is individually 
listed as well as being located within a registered 
historic district. The proposed "pedway" would enter 
the arched window in the limestone base four bays 
from the corner closest to the park. 




5. This rendering of the proposed "pedway" shows that the architect took great care 
to reduce the loss of historic materials. The project, however, was denied 
certification as a result of the drastic change this elevated bridge would have on the 
formal facade of this significant architectural resource. 



85-075 







CUMULATIVE 
INDEX 

Volume 1: 001-043 

Volume 2: 044-075 

Abrasive Cleaning 
009, 039 

Additions to Buildings 

See Also: Greenhouses 

Storefronts 
Demolition of Additions 

016,018,045 
New Designs 

010, 022, 026, 027, 028, 034, 037, 045, 051, 058, 072, 075 
Rooftop Additions 

034,048,051,060,071, 074 

Administrative Issues 

See: Previous Owner 

Air Conditioning 
014 

Aluminum Siding 

See: Artificial Siding 

Arcades 
030 

Artificial Siding 
005, 006, 070 

Atrium 
048 

Balconies 

See Also: Porches, Galleries 

048 

Brick 

Mitigating damage of abrasively cleaned masonry 

009 
Painting previously unpainted brick 

011, 029 

Removing interior plaster to expose brick 
013 

Brownstone 

See: Sandstone 



Building Codes 
Elevator 

059 
Fire safety 

037 
Handicapped access 

032 

Ceilings 

See: Interior Spaces, Alterations 

Chemical Cleaning 
063 

Cleaning, Damaging Methods 
See: Abrasive Cleaning 
Chemical Cleaning 

Complexes 

See: Demolition, Buildings within Complexes 

Courtyards 

See: Atrium 

Demolition 

See Also: Interior Spaces and Features, Alteration 
Buildings within complexes 

012, 041, 0*3 
Demolition/alteration of non-original features that have achieved significance 

016, 018,027,041,073 
Significant fabric and features 

032, 039, 048, 072 

Deteriorated Buildings, Features and Materials, Repair versus Replacement 
029, 031, 038, 040, 042, 043, 054, 055, 056, 064, 067, 069 

Doors and Entranceways 

See Also: Interior Spaces and Features, Alteration 
New openings 

029,047, 049,050 
Removal or replacement of entrance 

004, 015, 025, 032, 045, 049, 050, 061, 067 

Entrances 

See: Doors and Entranceways 

Environment 

See: Setting 

Exterior Surfaces 

See: Artificial Siding 
Brick 

Paint, Removal of 
Replacement Materials 
Sandstone 
Wood 



Fireplaces 

See: Interior Spaces and Features, Alteration 

Floor Plans, Changes to 

019,020,026,051,054, 065 

Galleries 

See Also: Porches 
New construction 
008 

Gardens 

See: Setting 

Greenhouse Additions 
007, 022, 045 

Historically Inappropriate Alterations and Additions, Construction of 
See Also: Brick, Removing interior plaster to expose brick 
004,005,008,018,024, 029 

Insulation, Urea-formaldehyde Foam 
023 

Interior Spaces and Features, Alteration 
See Also: Floor Plans 
017, 019, 020, 024, 047, 054, 059, 065, 066 

Limestone, Replacement 
055 

New Construction 

See: Additions to Buildings 

Environmental/Setting, Alterations 

Greenhouses 

Historically Inappropriate Alterations 

Infill Construction 

Porches 

Roof Alterations 

Storefronts 

Paint 

See Also: Abrasive Cleaning 
Mitigating damage to exterior by painting 
009, 042 

Painting previously unpainted surfaces 

011,029 
Retention of unpainted surfaces after paint removal 

036, 039 

Pedestrian Bridges 
075 



Plan, changes to 

See: Floor Plans 

Plaster, Removal of 

See Also: Interior Spaces and Features, Alteration 
013 

Porches 

See Also: Galleries 
Alteration/Demolition 

006, 018, 033, 039, <M, 054, 072, 073 
Enclosures 

001,033 

Previous Owner, Project Work Undertaken by Previous Owner Which Does Not 
Meet the Standards 
001 

Regulations, Project Work Undertaken Prior to Issuance of 
018, 028 

Replacement Materials 

See: Artificial Siding 
Brownstone 
Doors 
Limestone 
Roofing 

Sandstone, Replacement of 
Windows 
Wood 

Roof Alterations 

See Also: Additions, Rooftop 
031,038,051 

Sandblasting 

See: Abrasive Cleaning 

Sandstone, Replacement 
040, 056 

Setting 

002, 068 

Siding 

See: Artificial Siding 

Wood, Replacing clapboarding with shingles 

Site 

See: Setting 

Skywalks 

See: Pedestrian Bridges 



:. 



Stairtower 
037 

Standards for Evaluating Significance Within Registered Historic Districts 
064, 070 

Standards for Rehabilitation, Secretary of the Interior's 

Standard 1 (Compatible New Use) 
020, 028, 033, 047 , 053, 065, 066 

Standard 2 (Retention of Distinguishing Architectural Character) 

001, 002, 003, 006, 011, 012, 013, 014, 015, 017, 019, 020, 021, 022, 023, 025, 026, 
028, 029, 030, 032, 033, 036, 039, 041, 043, 044, 045, 047, 048, 049, 050, 051, 052, 
053, 054, 055, 056, 057, 058, 059, 060, 061, 062, 065, 066, 069, 071, 073, 074, 075 

Standard 3 (Recognition of Historic Period) 

004, 005, 006, 008, 010, 024, 029, 046, 054, 055 ,056, 061 

Standard 4 (Retention of Significant Later Alterations/Additions) 

012, 016, 018, 025, 027, 031, 041, 043, 053, 054, 061, 062, 073 
Standard 5 (Sensitive Treatment of Distinctive Features and Craftsmanship) 

011,014, 017, 020,025,029,032, 033, 047, 048,053,054, 058,059,062, 065, 073 
Standard 6 (Repair/Replacement of Deteriorated or Missing 
Architectural Features Based on Historical Evidence) 

013, 015, 029, 031, 032, 035, 038, 040, 042, 046, 049, 052, 054, 055, 056, 057, 059, 
061, 065,067,069,072, 073 

Standard 7 (Cleaning with Gentlest Method Possible) 

009, 039, 063 
Standard 8 (Protection/Preservation of Archeological Resources) 
Standard 9 (Compatible Contemporary Design for New Alterations/Additions) 

001, 003, 007, 010, 014, 022, 028, 030, 031, 034, 037, 045, 046, 048, 049, 050, 051, 

058, 060, 065, 066, 067, 071, 072, 074, 075 
Standard 10 (Reversibility of New Alterations/Additions) 

026, 037, 047, 048, 051, 066 

Storefronts 

003, 004, 027, 030, 049, 050, 053, 061, 062, 067, 070, 073 

Streetscape 
075 

Stucco 

040 

Surface Material, Nonhistoric 
005, 070 

Timing 

See: Project Work Undertaken Prior to Issuance of Regulations 

Vinyl Siding 

See: Artificial Siding 



Windows 

See Also: Storefronts 
Alteration/Demolition 

015,031,032,046,048,075 
New Openings 

050 
Replacement 

021,029,035, 046,052,057 




Wood 



Abrasive cleaning 

039 
Removing interior woodwork 

017 
Removing paint from previously painted wood 

036, 039 
Replacing clapboarding with shingles 

042 





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U. S GOVERNMENT PRINTING OFFICE 1985 486-032/32920 



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